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VAT threshold of 8 million RSD: how it works and what to do next

Admin8 min

The VAT registration threshold in Serbia in 2026 is 8,000,000 RSD of total turnover in the previous 12 months. Once you cross it, entering the VAT system is mandatory and the registration form is due within 5 days. The point most business owners miss: the threshold is not measured per calendar year but on a rolling basis, over the last 365 days, at any point in time. This article explains what counts as turnover, walks through a rolling-period example, covers what happens to a lump-sum entrepreneur who enters VAT, and gives a 5-step checklist for your first month in the system.

What counts toward the VAT threshold

Total turnover for the threshold includes supplies of goods and services whose place of supply is Serbia. It is the value of supplies made, excluding VAT, regardless of whether they have been paid. Specifically:

Counts toward the thresholdDoes not count
Taxable supplies in Serbia at 20% and 10%Services to foreign businesses with the place of supply outside Serbia (for example IT, marketing or consulting services for a client in the EU or the US)
Exempt supplies with the right to deduct input VAT (export of goods, international transport)Exempt supplies without the right to deduct (certain financial, medical and educational services)
Supplies to both domestic and foreign customers when the place of supply is SerbiaSales of equipment and premises that are your fixed assets

The place-of-supply rule is why an IT contractor with 10 million RSD of revenue from clients in Germany and the US can stay outside the VAT system, while a restaurant with 8.1 million RSD of sales in Belgrade must register. We cover this in our article on accounting for IT companies.

The rolling 12-month period: a worked example

The threshold is tested on the date of each supply, looking back 12 months. Take a service company with growing monthly sales in Serbia:

MonthTurnover in the month (RSD)Trailing 12-month total (RSD)
October 2025500,0004,900,000
November 2025550,0005,150,000
December 2025600,0005,400,000
January 2026600,0005,650,000
February 2026650,0005,950,000
March 2026700,0006,300,000
April 2026700,0006,650,000
May 2026750,0007,050,000
June 2026750,0007,450,000
July 2026800,0007,800,000
August 2026850,0007,450,000
September 2026900,0008,350,000

Entering September 2026, the total for October 2025 through August 2026 is 7,450,000 RSD, so the company is 550,000 RSD short of the threshold. If an invoice on September 18 brings September sales to 600,000 RSD, the threshold is crossed on September 18 and the EPPDV registration form must be filed by September 23. The trailing totals for earlier months assume sales in 2024 and 2025 and are for illustration only.

Note that in calendar 2026 the company has only 6.7 million RSD of sales through September. Looking at the calendar year alone, it would think it was far from the threshold. Track turnover monthly, and once you pass 6 million RSD in the trailing 12 months, check the total before every larger invoice.

What to do when you cross the threshold

  1. File the EPPDV registration form through the ePorezi portal within 5 days of crossing the threshold. The Tax Administration issues a VAT registration certificate.
  2. Start charging VAT on supplies made after the threshold was crossed. The invoice that crosses the threshold generally does not itself carry VAT, but confirm this with your accountant, since it depends on the supply date and the type of service.
  3. You stay in the system for at least 2 years. Deregistration is possible only after that period, if turnover falls below the threshold.

If you are below the threshold but most of your customers are VAT payers, consider registering voluntarily. Our voluntary VAT registration article explains when that makes sense, and the full procedure is in the VAT registration guide.

Lump-sum entrepreneurs entering VAT

A lump-sum (paušalni) entrepreneur who becomes a VAT payer loses the right to lump-sum taxation and must keep books under single-entry or double-entry accounting. Tax is then paid on actual profit rather than on a fixed assessment, and regular bookkeeping becomes necessary.

The two limits work differently. The lump-sum limit of 6,000,000 RSD is measured per calendar year and covers all turnover. The VAT threshold of 8,000,000 RSD is rolling and covers only supplies with the place of supply in Serbia. An entrepreneur with domestic clients will therefore usually lose the lump-sum regime first, at 6 million, and enter VAT later. An entrepreneur with foreign clients can have 10 million RSD of revenue and remain outside VAT, but still loses the lump-sum regime.

Your first month in the VAT system: 5 steps

  1. Fix your invoices and SEF. Invoices must show your tax ID, the supply date, the base, the rate (20% or 10%) and the VAT amount. Update your VAT status in the e-invoicing system and in your invoicing software.
  2. Recalculate prices and inform customers. For customers who are VAT payers the net price stays the same, they deduct the VAT. For consumers, decide whether to absorb VAT in the current price or raise it. Consumer price lists must show VAT-inclusive prices.
  3. Set up VAT records. Every purchase invoice with VAT now has value, because input VAT reduces what you owe. Make it a rule that every VAT receipt is issued to the company's tax ID and handed to the accountant in the same month.
  4. Count your inventory. For goods held in stock on the day before VAT registration you can, with an inventory list and supplier invoices, claim input VAT. Confirm the deadline and conditions with your accountant before the first return.
  5. Put deadlines in your calendar. A taxpayer that starts VAT activity for the first time files the PP PDV return monthly for the current and the following calendar year, regardless of turnover. The return and payment are due within 15 days after the end of the month. Only after that, if turnover stays below 50 million RSD, do you move to quarterly filing.

Common mistakes

  • Measuring the threshold per calendar year instead of the previous 12 months.
  • Including exported services to foreign businesses in the threshold, or excluding exports of goods, which do count.
  • Filing EPPDV late and then correcting invoices issued without VAT.
  • Throwing away purchase receipts in the first months and losing input VAT.
  • Assuming quarterly filing from day one. New VAT payers file monthly until the end of the following year.
  • Issuing invoices with VAT before registration, which is not allowed.

Frequently asked questions

Does the threshold count cash collected or invoiced turnover?

Invoiced turnover, meaning supplies made, regardless of payment. An invoice issued in December counts in December even if it is paid in February.

What if I crossed the threshold months ago and never registered?

The Tax Administration can assess VAT retroactively on all supplies after the crossing date, with interest and a misdemeanor fine. Register as soon as possible and work out the amount for the late period with your accountant. A voluntary correction is generally treated more leniently than an audit finding.

Can I stay a lump-sum entrepreneur if I am a VAT payer?

No. Entering the VAT system ends lump-sum taxation and you move to books. The reverse does not apply, you can keep books and stay outside VAT while below the threshold.

Does the 10% rate change the threshold calculation?

No. The threshold counts the value of supplies excluding VAT, whether the 20% or the 10% rate applies to them.

How NOTA GROUP can help

We monitor our clients' turnover monthly and flag the threshold before it is reached, and we manage the VAT entry from the EPPDV form to the first PP PDV return. See our accounting services or book a consultation if you are not sure where you stand against the threshold.

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