Notification on registration for System of Electronic Invoices in Serbia

 

On June 30th, 2022, the Ministry of Finance issued a notification regarding the registration and usage of the System of Electronic Invoices (SEI), reminding all entities, regardless of whether they are obligated to register for SEI or not, that private sector entities are obligated to store and keep the e-invoices regardless of whether they are issued by the private or public sector entities.

Also, the Notification states that in case the issuance of e-invoices is mandatory and the recipient is a private sector entity that is not registered for e-invoicing, the Tax authority will automatically register the private sector entity (as a recipient) for SEI and the e-invoice will be stored in his account. This doesn’t mean that all entities will be registered automatically but only entities that are obligated or if they become obligated to register for SEI and that are obligated to store the e-invoices.

In case of automatic registration for SEI, the Tax authority will inform the taxpayer only in case the taxpayer has left the email address in Business Register Agency, this means that if taxpayers haven’t left their email address the notification would not be delivered to them, thus the taxpayers they haven’t left their address should contact the Tax Authority and their accountants (it is recommended to register an email address in Business Register Agency).

Please find below the brief overview of obligations in line with the Law on Electronic Invoicing:

The subject of obligation to issue electronic invoices are:

    1. Private sector entity
      • VAT payers (entities registered for VAT)
      • Non-VAT payers (on voluntary basic)
    2. Public sector entity
      • State authorities (all state bodies and authorities)
      • Public enterprises (founded by the state or entities finances by the state)
    3. Tax representative of foreign company
      • All entities registered as tax representatives of foreign companies

According to Article 24 of the Law on Electronic Invoicing, starting from July 1, 2022, the obligation of private sector entities is to receive electronic invoices issued by public and private sector entities, which are sent through the SEI.

   Mandatory for the subject of private sector

   In force as of

   Receipt and storage of electronic invoices (issued by public and private sector entities)    July 1st, 2022.
   Receipt and storage of electronic invoices (issued by public and private sector entities)    July 1st, 2022.
   Recording of VAT calculation except for transactions in which one of the parties is a public sector entity    July 1st, 2022.

 

Mandatory for the subject of public sector

In force as of

 Issuance of electronic invoice to a private sector entity July 1st, 2022.

 

Exemptions from the obligation to issue an electronic invoice through the SEI:

  • Retail supply and received advance for retail supply in accordance with the law governing fiscalization, because the new fiscal devices will send fiscal invoices to the SEI, with the fact that it will be mandatory to enter the PIB on the fiscal account.
  • Contractual obligations directed towards the beneficiaries of funds from international agreements
  • Supply, modernization and overhaul of weapons and military equipment, procurement of security-sensitive equipment, as well as related procurement of goods and services

 

Recommendation

  • In case you are a VAT register taxpayer and you have left your email to the Business register Agency please doublecheck your email inbox and contact your accountant
  • In case you are a non-VAT registered taxpayer, and you have not left your email address please contact your accountants and Tax authority to check whether the account on SEI is opened or not.

 

In Belgrade, July 5, 2022.