Did you know that as of January 1, 2025 (and some provisions starting from January 1, 2026), significantly revised rules governing the work of the Tax Administration, taxpayer records, and methods of tax collection have come into effect? These amendments to the Law on Tax Procedure and Tax Administration (“Official Gazette of RS”, no. 94/2024) could impact every segment of your business — from company registration and structural changes to individuals who will now be included in a completely new “digital record.”
Below, you will find a detailed overview of the most important changes, along with recommendations on how to comply with the new rules in time and avoid unnecessary penalties or difficulties.
Why Do These Amendments Change Existing Practice?
Clearer definition of the end of tax obligations
More precise conditions have been introduced for when a tax is considered “written off,” including in cases of company closure, statute of limitations, or uncollectability.
Creation of a centralized electronic record of individuals
The Tax Administration will gain broad access to citizen data by consolidating records from various institutions. This means fewer “loopholes” in the system and quicker detection of irregularities.
More flexible organization of the Tax Administration
Instead of rigid, legally defined jurisdictions, the distribution of duties among Tax Administration units will now be more efficient and governed by internal acts.
New “flexible” monetary penalties
Instead of a uniform approach, the penalty amount will depend on the extent of damage caused to the budget. Minor mistakes – lower fines, and vice versa.
Key Dates
- December 2024 – The date the amendments formally come into effect.
- January 2025 – Most provisions begin to apply.
- January 2026 – Provisions related to individual records, foreign currency tax payments, and some specific procedures are postponed until 2026.
Tip: Don’t wait until the last minute to familiarize yourself with the new rules. Although some provisions apply from 2026, early preparation will prevent unpleasant surprises.
Individual Records – A Step Toward Comprehensive Monitoring
What is the new individual database?
The law mandates the Tax Administration to create a dedicated electronic database that collects data from:
- The Central Population Register
- The Central Registry of Mandatory Social Insurance
- The Ministry of Interior’s vehicle and firearms registries
- Records of the National Bank of Serbia
- Documents gathered during tax audits
Purpose:
This database aims to enable faster and more accurate determination of tax obligations and status (e.g., resident vs. non-resident), as well as to reduce the ability to “hide” income or assets.
Data protection and retention periods:
The Tax Administration will apply strict protection measures, with limited access to data (in accordance with the Personal Data Protection Law).
Data will be retained for 5 years after the individual’s death or 10 years from the date of deregistration if the person leaves Serbia.
New Procedures for Company Closure and Structural Changes
Transfer of debt to legal successor
If company “A” merges with or sells its entire stake to company “B” (or changes legal form), all debt transfers to the new or existing entity — even if “B” was unaware of the debt.
After deletion of the company from the Business Registers Agency, tax returns are submitted by the legal successor’s representative or another legally designated person.
This measure prevents companies from “closing” just to avoid paying tax debts.
Death of an individual and successor liability
The deceased’s debt passes to heirs, but only up to the value of inherited property and according to their proportional share.
The Republic of Serbia, as the ultimate legal heir, does not assume such tax obligations (priority is given to other heirs or legal entities).
When and How Does a Tax Obligation End?
The law now clearly groups the reasons for termination of tax obligations:
- Collection – Regular or enforced.
- Statute of limitations – After legal deadlines expire (but if a mortgage or lien is recorded, collection is still possible through that collateral).
- Debt discharge – May be by decision of the Tax Administration or the Government when specific conditions are met.
- Permanent uncollectability – If the taxpayer is deleted from the register, has no heirs or collateral (mortgage, lien).
Note: If a mortgage or lien is recorded, the statute of limitations does not prevent debt collection at least from the pledged asset.
Restrictions on Business Deregistration and PIB Revocation
- Ban on deleting legal entities or entrepreneurs from the register while a tax audit is ongoing or the Tax ID (PIB) is “temporarily revoked.”
- Until now, this ban applied only in cases of suspected tax crimes. Now, it also includes any active tax control or sanctions process by the Tax Administration.
Tax Payment in Foreign Currency and Debt Repayment Plans
Non-residents: paying in foreign currency
The law introduces the possibility for non-residents to pay tax from abroad directly to the Tax Administration’s foreign currency account.
Detailed conditions (currency, exchange rate calculations) will be regulated by a Ministry of Finance bylaw, within 6 months after December 6, 2024.
Deferred payment (repayment plans)
No more discretionary rights for the Tax Administration. If you meet the legal conditions for deferment (e.g., not related to annual personal income tax), the Tax Administration is obligated to approve the plan.
Statute of Limitations and Discharge of Obligations – What’s New?
- A taxpayer may file a request for a decision on tax obligation termination due to statute of limitations as soon as the legal deadline passes.
- The Tax Administration may also act ex officio and issue a decision to that effect.
- “Debt write-off” is now called “discharge” in the legal text, and a new term is introduced: “permanent uncollectability” – when no person or entity can assume the debt and there is no collateral.
Monetary Fines – Tiered by Amount of Debt
The new Law introduces a clear range of fines for different violations:
Failure to file returns or calculate tax
The fine ranges from 20% to 65% of the unpaid tax, with a minimum amount (e.g., RSD 300,000 for legal entities).
Late payment
Divided into categories:
- For delays under RSD 100,000, the fine is RSD 25,000 for legal entities
- For amounts over RSD 10,000,000, the fine increases to RSD 300,000
Individuals
Lower fines, but still progressive:
- For debts up to RSD 50,000, the fine can be RSD 10,000
- For over RSD 1,000,000, fines can reach up to RSD 50,000
Key effect: Larger violations – higher fines. Small oversights = smaller penalties. However, repeat offenses or high debts will become serious legal problems.
Doubtful and Disputed Claims
The law introduces the terms “doubtful” or “disputed” claims. These refer to obligations where the taxpayer is in bankruptcy, liquidation, has died, or has been declared incompetent or missing. These debts are monitored in a special regime until the final outcome is determined — whether they are partially or entirely collectible or will be declared uncollectable.
Debt Discharge for Previously Deleted Entities
A specific provision allows for the automatic discharge of debts owed by companies deleted from the register by a certain date (e.g., December 31, 2019, or December 31, 2024, depending on the case), if no liability proceedings were initiated and no lien was recorded.
This applies to companies removed due to non-compliance with regulations, bankruptcy, etc.
What Steps Should You Take?
- Read the new Law in detail
It may seem extensive at first glance, but these are key elements to understand your new obligations. - Adapt internal procedures
If you’re preparing for a merger, acquisition, or liquidation, check for outstanding obligations. - Consider repayment plans if you cannot settle your debt immediately.
- Be timely with filings
Given the new penalty system and automatic debt transfers to successors, timely tax filings are more important than ever. - Consult legal and tax professionals
If this all seems too complex, a professional advisor or agency can help prevent unpleasant situations and unnecessary costs. - Check if you can reduce risks
Determine whether you (as an individual) or your company own assets listed in public registries (vehicles, real estate, firearms).
The Tax Administration will soon have “everything in one place,” so the best tactic is to be transparent and up to date.
Conclusion: Smart Planning Prevents Complications
While the new Law introduces additional obligations and detailed procedures, its goal is to strengthen legal certainty and efficient tax collection.
Most importantly:
- Understand that any change in company status or closure automatically transfers all “baggage” to the successor
- Know that individuals will be monitored through a centralized system starting in 2026 — making it easier for the state to check tax compliance
- Recognize that penalties are now directly tied to unpaid tax amounts, so even small mistakes can be costly, and major violations won’t fly under the radar
Final recommendation:
Take time to review your or your company’s situation. Identify possible weaknesses (late filings, outstanding debts, non-residents needing to pay tax from abroad, etc.).
The earlier you act, the fewer unpleasant surprises await you — in both 2025 and 2026.
If you need additional interpretation, don’t hesitate to contact an accounting agency or tax advisor.
Investing in professional help always costs less than potential interest and penalties.
Taxes can be a burden or an opportunity – choose to adapt in time and take advantage of the new rules, instead of facing heavy fines and future problems. Good luck!
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