Starting from January 1, 2023, the obligation to issue and keep electronic invoices in transactions between VAT companies and the private sector comes into effect.
The deadline for implementing e-invoices has arrived. This is the new (government) Electronic Invoice System through which e-invoices will be sent and received. Business entities can access it directly or through an information intermediary.
Quick overview of e-invoice implementation deadlines
According to the current law on electronic invoicing, both the public sector and the entire economy are obliged to use electronic invoices in their daily activities. However, the introduction of e-invoices will be gradual.
| Obligation for private sector entities | Implementation Deadline |
|---|---|
| Issuing electronic invoices to public sector entities | May 1, 2022 |
| Receiving and storing electronic invoices (issued by public and private sector entities) | July 1, 2022 |
| Issuing electronic invoices to private sector entities | January 1, 2023 |
| Registration of VAT calculations, except for transactions involving a public sector entity | January 1, 2023 |
| Obligation for public sector entities | Implementation Deadline |
|---|---|
| Issuing electronic invoices to public sector entities | May 1, 2022 |
| Receiving and storing electronic invoices (issued by public and private sector entities) | May 1, 2022 |
| Registration of VAT calculations | May 1, 2022 |
| Issuing electronic invoices to private sector entities | July 1, 2022 |
What e-invoice deadlines apply to private firms in the VAT system
The accounting act related to mandatory electronic invoicing from 2022 has brought about certain changes when it comes to the mandatory issuance of electronic invoices for VAT taxpayers.
Business entities will be able to access the new Electronic Invoice System directly or through information intermediaries. The obligation to issue and store electronic invoices for exchanges among VAT taxpayers will apply from January 1, 2023. In addition to VAT taxpayers, other business entities from the private sector will be able to voluntarily access the Electronic Invoice System.
And what deadlines apply to lump-sum taxpayers?
Private sector companies that are not VAT taxpayers, such as lump-sum taxpayers, for example, are not required to register on the Electronic Invoice System automatically. However, lump-sum taxpayers conducting business with the public sector must register on the Electronic Invoice System. This means that, even though they are not VAT taxpayers and do not belong to the public sector, lump-sum taxpayers must register on the Electronic Invoice System as voluntary users if they want to invoice services and goods to the public sector. If they do not register on the Electronic Invoice System voluntarily, the deadlines do not apply to them. If they do register voluntarily, they are subject to all the rules that apply to other VAT taxpayers.
Who is not subject to the e-invoice deadline?
The issuance of electronic invoices will not be mandatory for invoices related to:
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Retail and received advances for retail trade
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Contractual obligations to recipients of funds from international framework agreements
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Weapons and military equipment;
Electronic Invoice System and electronic invoicing standard
For issuing, sending, receiving, and storing e-invoices, the Electronic Invoice System is used. The e-invoice system is defined as an information technology solution for sending, receiving, recording, processing, and storing e-invoices, managed by a central information intermediary. The issuance and receipt of e-invoices are done in accordance with Serbian electronic invoicing standards (standards set by the national standardization body in Serbia), which are largely aligned with European electronic invoicing standards.
What are the mandatory elements of an e-invoice?
The Law on VAT prescribes the elements that an e-invoice must contain: the identification number of the recipient and issuer, invoice details, payment instructions, and more. The Regulation on the elements of an electronic invoice, the format and method of delivering documentation through the Electronic Invoice System, the method and procedure for electronic recording of VAT calculations in the Electronic Invoice System, and the application of electronic invoicing standards have also been established. It states that the basic elements of an e-invoice are:
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Company name or abbreviated name, i.e., name, address, VAT ID, and identification number of the e-invoice issuer
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Business account of the e-invoice issuer
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Business name or abbreviated business name, i.e., name, address, VAT ID, and identification number of the e-invoice recipient
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Business account of the e-invoice recipient
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Serial number, date, and place of issuance of the e-invoice
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Date of delivery of goods or provision of services or advance payment
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Amount of advance payments, if applicable
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Payment instructions
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Information about the type and quantity of delivered goods or the type and scope of provided services
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Base amount for VAT
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VAT tax rate
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Amount of VAT calculated on the base amount;
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Total amount of the e-invoice;
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Note on the provision of the law that regulates VAT, based on which VAT was not calculated
The deadline is January 1, 2023, so don't wait.
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Frequently Asked Questions
- When it comes to the private sector, is it required to keep e-invoices, or is it sufficient for them to be in the Electronic Invoice System (SEF)?
- If I belong to the private sector, what is the deadline for sending e-invoices?
- If I am not a VAT taxpayer, do I have to send e-invoices from January 1, 2023?
No, SEF is sufficient. E-invoices of the private sector are stored in SEF and do not need to be stored separately elsewhere.
From January 1, 2023, sending e-invoices is mandatory.
Sending e-invoices is not mandatory if the company is not a VAT taxpayer. If it voluntarily registers on the SEF portal, then it is subject to all the rules that apply to VAT taxpayers.
For all technical details, situations, and general information about e-invoices, please review the list of frequently asked questions and answers.
