Serbian businesses are facing simultaneous changes to beneficial ownership, corporate taxation, digital reporting, competition law and environmental taxation, creating new compliance requirements for companies and corporate groups. The regulatory changes include a new beneficial ownership regime that took effect, amendments to corporate tax rules adopted, updated requirements for electronic VAT and delivery-note systems, and deadline for certain distribution and other vertical agreements to comply with revised competition rules. The measures affect ownership documentation, investment incentives, accounting systems, commercial contracts and carbon-related tax obligations.
New Beneficial Ownership Documentation Requirements
Serbia’s new Law on the Central Records of Beneficial Owners became applicable on September 15. Existing registered entities have 60 days from the start of application to comply with the new requirements. The regime covers companies other than public joint-stock companies, along with cooperatives, branches of foreign companies and other registered entities specified by the legislation. Companies must now maintain and upload documentation supporting the determination of their beneficial owner, rather than only registering the owner’s identity.
The Serbian Business Registers Agency (APR) has said the system enables authorities and entities subject to anti-money laundering requirements to compare registered information with ownership data obtained through their own due-diligence procedures. Companies with international ownership structures therefore need their shareholder records, group ownership charts, foreign corporate documentation and beneficial-owner declarations to remain consistent.
Corporate Tax Incentives Enter Transition
Parliament adopted amendments to the Corporate Income Tax Law, with the changes entering into force and generally applying from 2027. The amendments phase out the investment and employment incentive under Article 50a. Companies that satisfy the qualifying requirements can continue using the incentive under the previous rules for the remainder of the eligible period. The abolition applies from 2028. The incentive available to newly established innovative companies is also being withdrawn. Businesses that meet the relevant requirements, 2026 can retain the benefit under transitional provisions.
The amendments also remove withholding tax on purchases of secondary raw materials from January 1, 2027. Additional provisions incorporate elements of several EU tax directives, covering mergers, parent-subsidiary relationships, interest and royalty payments and anti-tax avoidance. These provisions are intended to become applicable when Serbia joins the European Union.
VAT and Electronic Reporting Requirements Expand
Changes involving VAT, electronic invoices, electronic delivery notes and fiscalisation are increasing the role of accounting and enterprise resource planning systems in tax compliance. The amendments adopted on August 31 provide for further integration between electronic invoicing and VAT reporting, with major elements becoming applicable from 2027. Changes to VAT implementing rules introduce a preliminary VAT return generated through Serbia’s electronic invoicing system using information already contained in the platform.
Amendments to electronic delivery and receipt notes also entered into force on September 8. Under the transitional arrangements, errors in data contained in those documents will generally not be taken into account during inspections. The transition affects businesses including manufacturers, wholesalers, logistics companies and large retailers that need to coordinate physical goods movements with electronic reporting.
September Deadline for Vertical Agreements
Companies also face a deadline under Serbia’s updated competition framework. The government adopted a regulation governing categories of vertical agreements exempt from the prohibition of restrictive agreements in March. It entered into force, replacing the previous framework from 2010. Existing agreements that qualified under the previous rules but fail to meet the new conditions were given six months to comply. The transition period expires.
The rules affect commercial arrangements including distribution, dealership, franchising and exclusive supply agreements. Companies are therefore required to assess contractual provisions concerning territories, customer groups, resale arrangements, online sales and other restrictions relevant to exemption from competition rules.
Carbon Tax Changes Affect Industrial Investment
Further requirements have emerged through amendments to Serbia’s greenhouse-gas emissions tax and the tax on imports of carbon-intensive goods. The amendments entered into force. Eligible electricity producers can receive a tax credit of up to 20% of eligible investment costs for measures designed to reduce carbon dioxide-equivalent emissions, subject to state-aid rules. The credit constitutes state aid, requiring companies to account for other public support received for the same investment when determining whether applicable aid-intensity limits have been reached. Special filing provisions apply to the first reporting period, with relevant 2026 tax returns generally due. The changes span ownership disclosure, corporate tax incentives, electronic tax administration, commercial agreements and carbon-related obligations, while several measures also incorporate elements of Serbia’s broader alignment with EU regulatory and tax frameworks.
