The Ministry of Finance, in coordination with the Tax Administration, released detailed technical guidance on 28 September 2026 regarding the proper recording of VAT discrepancies between final invoices and advance payments in the SAF-T (Standard Audit File for Tax) dataset, specifically when the VAT from the advance invoice was not previously claimed as input tax. This scenario arises when a taxpayer receives an advance invoice, pays the VAT, but does not report it in the VAT return for the period of receipt (e.g., due to cash-basis accounting or timing differences). Upon issuance of the final invoice, the VAT amount may differ due to price adjustments, discounts, or rate changes. The guidance clarifies that the difference must be reported in the SAF-T “Evidentija prethodnog poreza” (Input VAT Ledger) using specific adjustment codes: Code 45 for positive differences (additional VAT deductible) and Code 46 for negative differences (VAT to be reversed). The effective date for mandatory application is 1 January 2027, aligning with the new SAF-T schema version 2.1. Taxpayers using ERP systems must update their SAF-T export mappings to include these adjustment lines with proper references to both the advance and final invoice numbers.
Key Takeaways
- New SAF-T Adjustment Codes for Advance VAT Reconciliation: Taxpayers must implement Codes 45 and 46 in their SAF-T submissions to capture VAT differences between advance and final invoices when the advance VAT was not previously deducted. This ensures the Input VAT Ledger reflects the net deductible VAT accurately.
- Mandatory Cross-Referencing of Invoices: Each adjustment line must reference both the advance invoice (broj avansnog računa) and the final invoice (broj konačnog računa), including dates and VAT amounts. The Tax Administration will use automated cross-checks to verify consistency across the supplier’s and recipient’s SAF-T files.
- Transition Period and System Updates: Software vendors and in-house IT teams have until 31 December 2026 to deploy updates. Early adoption is encouraged; test submissions in the Tax Administration’s sandbox environment are available from 15 October 2026. Non-compliant SAF-T files after 1 January 2027 will be rejected, triggering late-filing penalties.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement