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Deadlines After Termination of the State of Emergency in Serbia

Deadlines After Termination of the State of Emergency

The Decision is effective as of 6 May 2020.

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On 6 May 2020 the Serbian Parliament adopted the Decision on Termination of the State of Emergency (hereinafter: the Decision) introduced on 15 March 2020. The Decision was published in the Official Gazette of the Republic of Serbia no. 65/2020 on 6 May 2020.

The Decision is effective as of 6 May 2020.

As we informed you earlier, on the date of termination of the state of emergency, being 6 May 2020, special tax measures introduced during the duration of the state of emergency are no longer effective. As a result, deadlines for meeting specific statutory requirements are reinstated which had been deferred due to the state of emergency, including deadlines within which taxpayers can exercise their right to protection of their legal interests by invoking particular legal means.

For reference purposes, a summary of the most significant implications of the termination of the state of emergency is presented below.

Special tax measures introduced during the duration of the state of emergency that are no longer effective

Taxpayer categories

Date of termination of state of emergency – 6 May 2020

Taxpayers under the regimen of deferred payment of tax liabilities

The prohibition against canceling agreements and revoking of decisions on postponement of taxes owed ex officio is no longer effective.

The prohibition against enforced collection of matured liabilities under the postponement regimen during the duration of the state of emergency is no longer effective.

Accrual of interest on postponed tax liabilities commences again.

VAT payers

The right to VAT exemption with the right to deduct input VAT on the supply of protective equipment (masks) is cancelled, where the National Health Insurance Fund (RFZO) conducts such supplies for entities that are engaged in distributing protective equipment (masks).

The right to VAT exemption with the right to deduct input VAT on the supply of goods and services without consideration performed by a VAT payer to the Ministry of Health, the National Health Insurance Fund or a publicly owned healthcare institution is henceforth revoked.

Taxpayers who have not settled their liabilities on time/are entitled to accrual of positive interest

The application of temporary accrual of interest at a rate equal to the National Bank of Serbia’s key policy rate on the amount of due but unpaid tax liability is hereby discontinued, including overpaid amounts of tax.

Starting as of 6 May 2020 interest on the amount of due but unpaid tax liability is accrued at the rate of 11.50% (instead of previous 1.50%).

 

 

Deadlines that are effective as of the date of termination of the state of emergency

As of the date of termination of the state of emergency deadlines presented in the table below shall go into effect:

Action/activity

Deadline - descriptive

Deadline expiry date

Filing of regular financial statements for 2019

90 days from date of termination of state of emergency

3 August 2020

Filing of consolidated financial statements for 2019

120 days from date of termination of state of emergency

2 September 2020

Filing of interim financial statements

30 days as of termination of the state of emergency, if the regular deadline (60 days as of the date on which interim financial statements are prepared) falls in the period of the state of emergency

4 June 2020

Filing of regular annual financial statements for companies whose financial year differs from the calendar year

90 days as of termination of the state of emergency, if the regular deadline (6 months as of the date on which financial statements are prepared) falls in the period of the state of emergency

3 August 2020

Filing of annual reports and financial statements with auditor’s report for all entities whose reporting requirements are regulated by the Law on Capital Markets or the Law on Investment Funds or the Law on Open Investment Funds With Public Offering

60 days from the date of termination of state of emergency

6 July 2020

Filing of corporate income tax return for 2019

90 days from the date of termination of the state of emergency

3 August 2020

Filing of corporate income tax return for a tax period other than the calendar year

90 day as of termination of state of emergency, if the regular deadline (180 days as of the expiry of the period for which tax is determined) falls in the period of the state of emergency

3 August 2020

Holding of regular shareholders’ meetings of joint stock companies

90 days from date of termination of state of emergency

3 August 2020

Submission of documentation in hard copy to the NBS based on which forms are certified on reporting about credit transactions of residents with foreign countries

10 days from of termination of state of emergency

15 May 2020

Filing of complaints to the Administrative Court against a final tax act issued during the state of emergency

30 days from date of termination of state of emergency

4 June 2020

 

Deadlines for invoking legal remedies in tax and customs proceedings

Deadlines for invoking legal remedies against first instance authority assessments and decisions by tax and customs authorities, issued in proceedings of assessment, payment, collection and auditing of public revenues during the state of emergency are presented below:

Action/activity

Deadline - descriptive

Date of filing/deadline expiry date

Regular submission of documents (assessments, decisions)

15 th day from the date of termination of the state of emergency

20 May 2020

Filing of appeals against first instance authority assessments and decisions by tax and customs authorities 

15 days from the date of receipt of first instance authority’s assessment/decision

4 June 2020

If you have any questions or you need assistance of our professionals, please contact us at tax@kpmg.rs

For previous editions of KPMG Tax Alerts please visit the following web page:

KPMG Tax Alerts


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Kraljice Natalije 11
11 000 Belgrade, Serbia
T: +381 11 20 50 500
F: +381 11 20 50 550
tax@kpmg.rs

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