Removed Uncertainties about the Issuance of Fiscal Invoices

Removed Uncertainties about the Issuance of Fiscal Invoices

November 02, 2022

An updated version of the Technical Guideline for Administrative and Technical Overview of Functionalities of ESIR or L-PFR – Version 1.14 (“Technical Guideline”) was published on the website of the Tax Administration on October 25, 2022.

Namely, considering the questions that frequently emerged in practice since the beginning of application of the Law on Fiscalisation (Off. Gazette of RS no. 153/2020) on January 1, 2022, about which we have previously written (available here and here), which replaced the Law on Fiscal Registers (Off. Gazette of RS no. 135/2004 and 93/2012) and introduced a completely new model of fiscalisation, this updated Technical Guideline eliminated several uncertainties with regards to:

  • issuance of fiscal invoices for advance payments prior to the application of eFiscalisation system;
  • keeping records of the sale of single-purpose vouchers and their using; and
  • issuance of fiscal invoices for free-of-charge turnover.

Below is an explanation of the respective changes.

Issuance of fiscal invoices for advance payments prior to the application of eFiscalisation system

As for the registering of advance payments, as well as their closing upon issuance of a fiscal invoice for a completed transaction, there is a specific situation when the advance payment has been partly or completely received prior to the application of the new fiscalisation model.

According to the updated Technical Guideline, upon closing (several) advance payments effected prior to the application of new eFiscalisation system, reference number of the last issued advance payment invoice is entered into the document Advance Refund, as well as the total amount of advance payment. However, if advance payments were partly done prior to the beginning of registration of transactions through new fiscal devices, and partly following the start of application of the new model, the Technical Guideline specifies the method of connecting fiscal documents.

Keeping records of the sale of single-purpose vouchers and their using

Pursuant to the updated Technical guideline, upon using of single-purpose vouchers no fiscal invoice shall be issued, but a receipt in terms of the regulations on trade or another accounting document outside the fiscalisation system.

Issuance of fiscal invoices for free-of-charge turnover

As regards this issue, it is considered that any free-of-charge turnover which, under the law governing the VAT, is equalised with charged transactions, shall be registered through fiscal devices.

Accordingly, i.e., in line with the Technical Guideline, the fiscal invoice shall include all of the prescribed elements, along with the following specific details:

  • in the field Name, before the name of the article, code 00: shall be entered (two zeros and a colon); and
  • in the field Manner of Payment, other non-cash form of payment shall be entered.

This article is to be considered as exclusively informative, with no intention to provide legal advice. If you should need additional information, please contact us directly.