On 12 October 2026, the Ministry of Finance issued an official opinion (Službeno mišljenje) addressing the accounting and VAT treatment of goods transferred without consideration (bez naknade) between suppliers, taxpayers, their customers, and potential customers. The opinion interprets Articles 18, 19, and 43 of the VAT Law alongside IAS 2 and IAS 20, confirming that such movements constitute deemed supplies subject to output VAT at the appropriate rate, while the recipient must recognize input VAT concurrently. The guidance mandates dual-entry recording: a debit to inventory or expense accounts at fair market value and a credit to a deferred income or liability account, subsequently released upon the taxable event. For promotional goods given to potential customers, the fair value is determined by reference to the most recent standalone selling price. The opinion also clarifies that VAT on deemed supplies becomes chargeable at the moment the goods leave the supplier’s warehouse, not at the point of final consumption, aligning with the EU Directive 2006/112/EC principles transposed into Serbian law.
Key Takeaways
- Deemed Supply Trigger: Any physical movement of goods without consideration between related or unrelated parties creates an immediate VAT liability at fair market value, requiring real-time invoicing via the e-invoice platform.
- Fair Value Hierarchy: Taxpayers must apply a strict valuation hierarchy: recent standalone sales price > comparable market price > cost-plus margin; documentation of the chosen method is mandatory for audit defense.
- Simultaneous Input/Output Recognition: Recipients must self-assess input VAT in the same period the supplier declares output VAT, preventing timing mismatches that previously led to assessment notices.
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