Serbia

New e-invoicing documents published B2G e-invoicing is expected to go live in 2022, and B2B e-invoicing in 2023. Considering the upcoming e-invoicing mandate, the Serbian Ministry of Finance has published some new documents. These outline the final specifications of the application interface for the e-invoicing system. XML formats based on the UBL 2.1 standard will be available for the following documents:

• Advance payment invoices;
• Invoices related to VAT exempted transactions;
• Public procurement invoices;
• Credit notes related to a certain period in time;
• Credit notes for multiple invoices;
• Debit notes related to multiple invoices;
• Debit notes related to a certain period.

Changes to the content of e-invoices Last month we outlined Serbia’s plan to implement e-invoicing in phased approach across the country within the next 2 years. Alongside the introduction of e-invoicing, we can expect some changes to the content of the invoice itself. In late 2021, the Minister of Finance in Serbia adopted a ‘rulebook’, which stated the following: • If a VAT invoice is submitted in e-invoice form, the place of issuance of the invoice does not need to be included; • There is a new mandatory element for a Serbian invoice- the advance payment invoice for an advance payment invoice. This ‘rulebook’ aims to synchronise rules on the issuance and content of VAT invoices with new regulations being introduced in respect of e-invoicing.

E-invoicing deadline postponed

While Serbia has made its intention to expand the use of e-invoicing in the country clear, the Minister of Finance has acknowledged that there will be a need to adapt to the new system. Therefore, there will be a transition period until the end of April 2022.  This means that the obligation of the public sector to receive and keep electronic invoices and to issue invoices to another public entity will apply from 1 May 2022, rather than 1 January 2022.

We earlier communicated around several other timeframes relating to Serbian e-invoicing and we still expect this to stand:

• the obligation of the private sector entity to receive and keep the electronic invoice issued by the public sector entity, as well as the electronic invoices issued by the private sector entity, will apply from July 1, 2022;
• the obligations of issuing and keeping electronic invoices in transactions between private sector entities take effect from January 1, 2023

E-invoicing demo environment

The e-invoicing demo environment is now live and can be found via the following link on the government website.

Public platform & Rulebooks

Serbia is moving towards an e-invoicing mandate. This will be a phased approach, with the following envisaged dates:

• 1 January 2022: Public sector entity to receive and keep an electronic invoice and issue invoices to other public sector entity (G2G) & Private sector entity to issue an electronic invoice to a public sector entity (B2G);
• 1 July 2022: Public sector entity to issue an electronic invoice to a private sector entity (B2G) & Private sector entity to receive and keep an electronic invoice issued by a public and private sector entity;
• 1 January 2023: To issue and keep electronic invoices in transactions between private sector entities (B2B).

Public platform & Rulebooks

Serbia is moving towards an e-invoicing mandate. This will be a phased approach, with the following envisaged dates:

• 1 January 2022: Public sector entity to receive and keep an electronic invoice and issue invoices to other public sector entity (G2G) & Private sector entity to issue an electronic invoice to a public sector entity (B2G);
• 1 July 2022: Public sector entity to issue an electronic invoice to a private sector entity (B2G) & Private sector entity to receive and keep an electronic invoice issued by a public and private sector entity;
• 1 January 2023: To issue and keep electronic invoices in transactions between private sector entities (B2B).

Law on electronic invoicing takes effect

The Law on electronic invoicing entered into force on 7 May 2021. There will be a phased introduction of e-invoicing with B2G invoicing due to take effect from 1 January 2022. Full implementation, including B2B invoicing, is expected from 1 January 2023. The new Law also introduces a requirement to electronically record VAT calculations within the electronic invoicing system. In addition, a new webpage was launched (https://www.efaktura.gov.rs/) by the Ministry of Finance. The webpage is specifically designed to cover updates concerning the e-invoicing project, implementation, and related topics. The testing environment of the e-invoicing system should in principle be made available to the users in July.

Law on electronic invoicing takes effect

The Law on electronic invoicing entered into force on 7 May 2021. There will be a phased introduction of e-invoicing with B2G invoicing due to take effect from 1 January 2022. Full implementation, including B2B invoicing, is expected from 1 January 2023. The new Law also introduces a requirement to electronically record VAT calculations within the electronic invoicing system. In addition, a new webpage was launched (https://www.efaktura.gov.rs/) by the Ministry of Finance. The webpage is specifically designed to cover updates concerning the e-invoicing project, implementation, and related topics. The testing environment of the e-invoicing system should in principle be made available to the users in July.

Publication of draft law on e-invoicing for B2B and B2G transactions

Serbia is making good progress with plans to move to mandatory e-invoicing and has published a draft version of the law on e-invoicing on the website of the Ministry of Finance. Note: it has not yet been passed by the National Assembly of Serbia.

The proposed law is looking to regulate:
• the issuance of electronic invoices for both B2B and B2G transactions;
• the national e-invoicing platform or system;
• the elements which e-invoices should contain; and
• e-archiving
The provisions of the law are supposed to come into effect from 1st July 2021 for B2G transactions.

For B2B transactions, reception and storage of e-invoices will be mandatory staring from 1 July 2022, and the issuance of invoices from 1 January 2023.

Publication of draft law on e-invoicing for B2B and B2G transactions

Serbia is making good progress with plans to move to mandatory e-invoicing and has published a draft version of the law on e-invoicing on the website of the Ministry of Finance. Note: it has not yet been passed by the National Assembly of Serbia.

The proposed law is looking to regulate:
• the issuance of electronic invoices for both B2B and B2G transactions;
• the national e-invoicing platform or system;
• the elements which e-invoices should contain; and
• e-archiving
The provisions of the law are supposed to come into effect from 1st July 2021 for B2G transactions.

For B2B transactions, reception and storage of e-invoices will be mandatory staring from 1 July 2022, and the issuance of invoices from 1 January 2023.