Belgrade Serbia capital overseeing the Danube River 

On April 29, 2021, Serbia published the Law on Electronic Invoicing. The framework is based on the clearance model (i.e., transmission and validation of e-invoices through a government portal). The framework is based on REST API which offers various methods to communicate with the government. The e-invoices must be issued in an XML format based on the UBL 2.1 standard and must contain specific codes indicating the type of invoices and VAT categories.

Subsequently, the implementation of the mandatory e-invoicing requirement was postponed to provide more time for taxpayers. The revised implementation dates are outlined below, based on taxpayer type.

For public sector entities:

    • May 1, 2022, for issuing e-invoices to other public sector entities

    • May 1, 2022, for receiving and storing e-invoices

    • May 1, 2022, for recording the VAT calculation in the e-invoices system

    • July 1, 2022, for issuing e-invoices to private sector entities

For private sector entities (i.e., VAT-registered taxpayers):

    • May 1, 2022, for issuing e-invoices to public sector entities

    • July 1, 2022, for receiving and storing e-invoices

    • January 1, 2023, for issuing e-invoices to private sector entities and performing other obligations

On July 9, 2021, Serbia published the following regarding the new e-invoicing obligations including

(1) a rulebook on e-invoice elements, 

(2) a rulebook on the registration to access the e-invoicing system, 

(3) a decree on the conditions and manner of using the invoicing management system; 

(4) a rulebook on the manner of acting of the Central Information Intermediary; 

(5) a decree on the procedure and conditions for issuing and revoking consent for performing the activities of an information intermediary; and 

(6) a decree on the conditions and manner of keeping and making available e-invoices and the manner of ensuring the authenticity and integrity of the contents of invoices in paper form. The rulebooks and decrees are effective January 1, 2022. 

Effective December 25, 2022, Serbia adopted amendments to the VAT Rulebook to harmonize rules on the issuance and content of VAT invoices. The amendments clarify that 

(1) a VAT invoice issued through an electronic invoicing system does not have to contain information on the place where the invoice is issued; 

(2) the date of advanced payment is a mandatory field on advance payment invoices; and 

(3) an invoice issued by a VAT taxpayer that records supplies via an electronic fiscal device is considered a VAT invoice. 

On March 1, 2022, the Serbian Ministry of Finance published a specification guide outlining the application interface for direct access to the e-invoicing system and examples of XLM files per the UBL 2.1 standard. 

On June 10, 2022, the Serbian tax authority published version 1.12 of the technical documentation of the e-invoicing system, which includes, among other things, the specifications for the application of standard EN-16931-1 and the e-invoicing system user interface guide. 

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