Amendments to several tax laws have been published in the Official Gazette of the Republic of Serbia, No. 80/2026, introducing changes that will have a significant impact on businesses in 2027 and 2028.
Law on Value Added Tax
- The amendments introduce more detailed rules governing VAT registration and deregistration, the cessation of VAT activities and the filing of VAT returns.
- In particular, an application for VAT deregistration must be submitted within five days from the date of cessation of VAT activities, while the final VAT return must be filed within 15 days.
- The amendments also further regulate situations in which a VAT payer ceases to exist as a result of a corporate status change, as well as the treatment of persons who failed to register for VAT within the prescribed deadline.
- The rules governing the minimum period during which VAT liability must be maintained are also amended and, in prescribed cases, linked to the current and following calendar year.
- Most of these amendments will apply as of 1 January 2027.
Law on Personal Income Tax
- As of 1 January 2027, the monthly non-taxable salary amount will increase to RSD 37,369 for full-time employees.
- The application of certain tax incentives for the employment of new employees has been extended through 2028, while the eligibility requirements for such incentives are also being amended.
- For the relevant incentives, entitlement will be linked to an actual net increase in the number of employees, measured against the average number of employees during the preceding 12 months, as well as compliance with State aid rules. Certain additional eligibility requirements will apply as of 2028.
- An important change also concerns entrepreneurs: a lump-sum entrepreneur who loses the right to lump-sum taxation and becomes required to maintain business books will, subject to the prescribed conditions, be able to opt for the payment of a personal salary.
Law on Mandatory Social Security Contributions
- The amendments largely follow the changes introduced under the Law on Personal Income Tax with respect to employment incentives. For the relevant incentives, stricter requirements are introduced regarding the increase in the number of employees and compliance with State aid rules.
- Importantly, the aggregate amount of the relevant tax incentive and social security contribution incentive may not exceed 50% of the salary costs of the newly employed persons or EUR 5.5 million per employer per year. Accordingly, employers will need to assess the applicable tax and social security contribution incentives as part of a single overall incentive framework, rather than separately.
Law on Corporate Income Tax
The amendments to the Corporate Income Tax Law are the most extensive and provide for several different dates of application. As of 2028, a number of existing tax incentives will be abolished, subject to transitional provisions allowing certain previously acquired rights to continue to be exercised until the expiry of the relevant prescribed period.
At the same time, a broader set of rules aimed at further aligning the Serbian corporate tax framework with EU tax law is being introduced, including rules concerning:
- Cross-border mergers, divisions and transfers of assets;
- Taxation of dividends, interest and royalties between associated companies;
- Limitations on the deductibility of financing costs;
- Controlled foreign company (CFC) rules;
- Hybrid mismatch rules and
- A general anti-abuse rule aimed at arrangements where one of the main purposes is to obtain a tax advantage contrary to the purpose of the law.
The amendments will be phased in: certain provisions will apply from 2027, others from 2028, while a number of rules introduced as part of the alignment with EU law will become applicable upon Serbia’s accession to the European Union.
For additional information or consultations, the Tasić & Partners team is at your disposal.