Starting with the January 2027 tax period (or January–March 2027 for quarterly filers), the VAT return in Serbia will no longer start from a blank form. SEF – the System of Electronic Invoices (Sistem elektronskih faktura), the government e-invoicing platform – will compile a preliminary VAT return on the basis of the data it already holds. The taxpayer reviews it, corrects any errors in the records kept in SEF and generates a new preliminary return. For many companies and sole proprietors, this is the biggest change in VAT compliance since e-invoicing was introduced.
In this article we explain what the preliminary VAT return is, what it consists of, what SEF fills in on its own, what you still have to enter yourself – and how to prepare before January.
What is the preliminary VAT return?
The preliminary VAT return (abbreviated PPP PDV) is a return that SEF compiles for a tax period on the basis of the data available to it, as at the day preceding the day it is compiled. Its form and content are governed by the Rulebook on Amendments to the Rulebook on Value Added Tax (Official Gazette of the Republic of Serbia, No. 71/2026), while the functionality within SEF is governed by the Rulebook on Amendments to the Rulebook on Electronic Invoicing (same issue of the Official Gazette). It applies from the January 2027 tax period – it was originally planned for 2026, but was postponed by one year by the amendments to the VAT Law (Official Gazette of the RS, No. 109/2025).
The Ministry of Finance has released the preliminary return module in the SEF DEMO environment, together with a user manual on efaktura.gov.rs. This means you can get to know the system before the obligation takes effect.
One point is essential: the preliminary return cannot be edited manually. SEF fills in the data automatically, and the user cannot directly change the automatically entered values. If something is wrong, the error is corrected in the relevant record in SEF and a new preliminary return is compiled, which automatically cancels the previous one. The return is therefore only as accurate as the data in SEF.
The preliminary VAT return in SEF: what it consists of
The preliminary return consists of three forms:
Form PPP PDV
The preliminary tax return itself. Its data are populated automatically from Annex 1 and Annex 2.
Annex 1 – data from the electronic invoicing system
Annex 1 contains data on the taxable amount (consideration) and VAT from SEF. Data are entered automatically on the basis of:
- issued and received electronic invoices,
- records relating to the electronic recording of VAT (individual and summary records, including internal invoices),
- the input VAT records.
Annex 2 – supplies of equipment and buildings
Annex 2 covers supplies of equipment and buildings used for carrying out business activities, and investments in such buildings. The taxpayer enters these data – SEF cannot extract them from invoices.
The preliminary VAT return and the new PP PDV form: what changes
Until now, the VAT return was the output of bookkeeping: the accountant aggregated the data from the records and filled in the form. From 2027 the direction is reversed – the state first “sees” your data through SEF, and you correct them not in the return but in the records themselves, before the return is compiled.
The same rulebook also prescribes a new PP PDV form (the VAT return). It is filed together with the preliminary return and additional annexes – Annex 3 (notification of purchases of secondary raw materials, agricultural and forestry products) and Annex 4 (VAT adjustments for previous tax periods).
Preliminary and final return – on the same day
The preliminary return and the PP PDV are filed on the same day. A preliminary return that was not compiled and submitted on the day the PP PDV is filed cannot be attached to it. Once the deadline has passed, SEF no longer allows a preliminary return to be compiled. If you are used to finishing VAT on the last day, you will have very little room for corrections.
If you do not file on time
This is the most important novelty. Under the amendments to the VAT Law (Official Gazette of the RS, No. 80/2026), if the taxpayer does not file the return within the deadline, the Tax Administration files it ex officio on the basis of the preliminary return. Such a return contains only output VAT, without input VAT. A delay therefore no longer means just a penalty: the liability under such a return may be several times higher than the actual one until you correct it.
Practical consequences
- Errors become visible immediately. A wrong rate on an e-invoice will flow into the preliminary return exactly as it is.
- Unprocessed incoming invoices cost you money. Input VAT enters Annex 1 from the input VAT records – an invoice you have neither accepted nor rejected will remain outside input VAT.
- Deadlines for records become more important. Anything not recorded on time will not be included in the preliminary return for that period.
- Reconciliation with the books becomes a monthly task, not something done just before the deadline.
Deadline
The deadline for filing the VAT return remains 15 days after the end of the tax period. For the first period under the new system – January 2027 – the deadline is 17 February 2027, because 15 and 16 February are the Statehood Day (Sretenje) public holiday.
How to prepare before January 2027
Here is a short checklist we recommend to all VAT payers, whether limited liability companies (d.o.o.) or sole proprietors keeping double-entry books:
Get your outgoing invoices in order
Check that the customer’s tax identification number (PIB), the VAT rate, the exemption basis and the date of supply are correct before sending. Correction after sending is possible, but it creates extra steps (cancellation and a new invoice).
Respond to incoming invoices regularly
Accept or reject every e-invoice you receive within the deadline, not at the end of the month. Unanswered invoices are the most common source of discrepancies between SEF and the books.
Keep your VAT records in SEF up to date
Internal invoices (e.g. for services supplied by foreign persons or domestic reverse charge) and the input VAT records feed directly into Annex 1. Late recording means the data will not be in the preliminary return for the correct period.
Get to know the module in DEMO SEF
The DEMO environment does not contain your production data, so comparing “from scratch” makes no sense. Use it to become familiar with the module and the workflow for compiling and submitting the return. For a more thorough test, re-enter the invoices and records for one month and compare the result with the return you actually filed.
Prepare the data for Annex 2
If you buy or sell equipment and buildings used for your business, decide who keeps these data and how, because SEF will not fill them in for you.
Move your internal deadline
Plan for the records to be completed a few days before the deadline, so there is time to correct an error and compile a new preliminary return.
Why this is good news for companies that keep their own books
The preliminary return rewards orderliness. Since it cannot be corrected manually, the only way for it to be accurate is to keep orderly records in SEF. If you work in SEF every day and keep your records up to date, the final return becomes a check rather than a build from scratch. This is exactly the model we believe in at Numerix: you keep your books with the help of modern tools, and we review them professionally – before the data become a return.
In practice, the biggest risk is not the return itself, but small errors that build up over the month: a wrong rate, a forgotten internal invoice, an invoice left unanswered. A systematic monthly review catches them before the deadline.
In brief
- From the January 2027 tax period, SEF compiles the preliminary VAT return (PPP PDV).
- It consists of the PPP PDV form, Annex 1 (automatically from SEF) and Annex 2 (entered by you); automatically entered values cannot be changed manually.
- The new PP PDV form is accompanied by Annexes 3 and 4; the preliminary and final returns are filed on the same day.
- If you do not file on time, the Tax Administration files the return for you – without input VAT.
- The deadline remains 15 days; the first one under the new rules is 17 February 2027.
Want to start 2027 without surprises?
If you are not sure whether your e-invoices and VAT records are ready for the preliminary return, get in touch. The Numerix team can review your SEF and books for one month and show you where the discrepancies are – before the Tax Administration sees them.
Sources: Rulebook on Amendments to the Rulebook on VAT (Official Gazette of the RS, No. 71/2026); Rulebook on Amendments to the Rulebook on Electronic Invoicing (Official Gazette of the RS, No. 71/2026); Law on Amendments to the VAT Law (Official Gazette of the RS, Nos. 109/2025 and 80/2026); efaktura.gov.rs – “Preliminary tax return in DEMO SEF” (31 July 2026) and the PPP PDV User Manual. This article is for information purposes only and does not constitute a tax opinion.
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