# Preduzmi > Every Preduzmi guide for Serbian lump-sum entrepreneurs (paušalni preduzetnici), in full, in one file. Each guide below cites Serbian legislation by article. Figures are stamped with the period they apply to; indexed dinar amounts in the income-tax and contributions laws are republished periodically and can change mid-year, so check the update date before quoting one. These guides describe procedure. They are not individual tax advice, and payment details should always be verified against your own tax decision (rešenje) and your bank's form. ## Guides - [How to Read a Serbian Paušal Tax Decision: Fields, Deadlines, Appeals](https://preduzmi.com/articles/pausal-tax-decision): A field-by-field guide to the annual tax decision (rešenje) for Serbian paušalci: where it is delivered, what the assessed base and the BOP mean, why the amount rose, and the 15-day appeal clock that starts the day it is posted. — 2026-08-19, updated 2026-08-21 - [Mirovanje vs Brisanje: Pausing or Closing a Serbian Paušal Business](https://preduzmi.com/articles/mirovanje-vs-brisanje): Mirovanje suspends your contributions under ZDOSO čl. 50; brisanje ends the business permanently. What each costs at APR in 2026, which documents you need, and the traps in both procedures. — 2026-08-12, updated 2026-08-21 - [Paušalac vs Freelancer in Serbia: Model A, Model B, and the Missing Allowance](https://preduzmi.com/articles/pausal-vs-freelancer): A paušalac is a registered entrepreneur; the frilenser regime is quarterly self-assessment by an unregistered individual. Compare Model A and Model B, the 110,647 RSD quarterly floor, and why a paušalac has no neoporezivi iznos. — 2026-08-04, updated 2026-08-21 - [Serbia's Annual Income Tax: Does Godišnji Porez Reach a Paušalac?](https://preduzmi.com/articles/annual-income-tax): Serbia's annual income tax counts a paušalac's assessed income, but the 2025 non-taxable threshold is 5,439,096 RSD. Rates, the 10,878,192 RSD tax-base bracket, PP GPDG and the 15 May 2026 deadline. — 2026-07-24, updated 2026-08-21 - [Registering as a Paušalac in Serbia: The First 30 Days](https://preduzmi.com/articles/registering-as-pausalac): A new paušalac elects paušal taxation inside the APR registration application itself, not through a separate 15-day filing. Eligibility, 2026 APR fees, and an ordered first-30-days checklist. — 2026-07-20, updated 2026-08-21 - [Does a Paušalac Need SEF? Serbia's E-Invoicing Rules in Four Questions](https://preduzmi.com/articles/sef-e-invoicing): Whether a Serbian paušalac must use SEF depends on four questions: VAT status, public-sector clients, voluntary registration, and nothing else. Plus the repealed CRF duty and the real e-otpremnice dates. — 2026-07-07, updated 2026-08-21 - [KPO Knjiga vs Bank Statement: Why the Two Totals Differ](https://preduzmi.com/articles/kpo-vs-bank-statement): Your KPO knjiga and your bank statement measure different things. The eight legitimate reasons the totals differ, why the 6,000,000 RSD limit counts invoices issued rather than payments received, and how to reconcile. — 2026-07-01, updated 2026-08-21 - [Serbian Paušal Tax Base: How It Is Calculated, and When Municipality Matters](https://preduzmi.com/articles/pausal-tax-base): The exact formula behind the Serbian paušal tax base — activity coefficient, municipality data, correction coefficients, the 10% annual cap — and why for activity code 6201 the municipality is not an input at all. — 2026-06-23, updated 2026-08-21 - [Late Paušal Tax Payment in Serbia: Interest, Penalties, and Enforced Collection](https://preduzmi.com/articles/late-payment-interest): What happens when a paušalac pays the monthly tax late in Serbia: the ZPPPA interest formula (NBS reference rate + 10 points), why the widely quoted +8 points is a different rate, and how enforced collection escalates. — 2026-06-11, updated 2026-08-21 - [Receiving Foreign Payments in Serbia: Raspored Priliva, Šifre, and Wise](https://preduzmi.com/articles/foreign-currency-inflows): How a devizni priliv reaches your account: the raspored deviznog priliva, šifra osnova naplate 302/305/307, the 909 suspense code, EUR invoices to domestic clients, and whether Wise and Payoneer are allowed. — 2026-06-06, updated 2026-08-21 - [How to Export an XLS Bank Statement from Alta Banka (Promet po računu)](https://preduzmi.com/articles/how-to-export-alta-xls): Step-by-step guide for paušalci: export your Alta Banka business account transactions as an Excel (XLS) file you can upload to Preduzmi in under a minute. — 2026-06-03 - [How to Export an XML Bank Statement from Raiffeisen (Moja eBanka biznis)](https://preduzmi.com/articles/how-to-export-raiffeisen-xml): Step-by-step guide for paušalci: export your Raiffeisen business account transactions as an XML file you can upload to Preduzmi in under a minute. — 2026-05-25 - [Eko Taksa for Paušalci: Serbia's Annual Environmental Fee, Explained](https://preduzmi.com/articles/eko-taksa): How much eko taksa costs, when to file Obrazac 1, where to pay, and what new paušalci need to know about Serbia's annual local environmental fee. — 2026-05-21, updated 2026-08-21 - [Agency vs Paušalac: The IT Freelancer's Decision Guide](https://preduzmi.com/articles/agency-vs-pausalac): Compare working through a Serbian agency versus running your own paušalac. Real numbers, independence test analysis, and a full side-by-side comparison to help you choose. — 2026-03-18, updated 2026-08-21 - [Paušalac vs Knjigaš: Which Serbian Tax Regime Is Right for You?](https://preduzmi.com/articles/pausalac-vs-knjigash): Compare paušalno oporezivanje (lump-sum taxation) with full bookkeeping for Serbian entrepreneurs. Tax calculations, break-even analysis, and a practical guide to choosing the right regime. — 2026-03-18 - [Preduzmi vs Excel: Why Spreadsheets Break Down for Paušal Compliance](https://preduzmi.com/articles/preduzmi-vs-excel): Feature-by-feature comparison of managing paušal obligations with spreadsheets versus Preduzmi. Learn where manual tracking fails and when a dedicated tool makes the difference. — 2026-03-18 - [The 2026 Paušalac Calendar: Every Deadline and First-Year Checklist](https://preduzmi.com/articles/calendar-checklist): Month-by-month calendar of every recurring obligation for Serbian paušal entrepreneurs, plus a complete first-year setup checklist for new preduzetnici. — 2026-03-16, updated 2026-08-21 - [Invoicing Foreign Clients as a Serbian Paušalac](https://preduzmi.com/articles/foreign-invoicing): Complete guide to invoicing foreign clients: mandatory fields, currency conversion, the PDV exemption, the double-count trap, and practical banking tips for Serbian paušal entrepreneurs. — 2026-03-16, updated 2026-08-21 - [Health, Sick Leave, and Pension Rights for Serbian Paušalci](https://preduzmi.com/articles/health-pension): What your monthly contributions actually buy: RFZO health coverage, sick leave rules (the 30-day gap), maternity benefits, pension accrual, and where the system falls short. — 2026-03-16, updated 2026-08-21 - [Serbia's Independence Test: All Nine Criteria for Contractors](https://preduzmi.com/articles/independence-test): Understand all 9 criteria of Serbia's independence test for paušal entrepreneurs. Learn what triggers failure, the financial consequences, and practical strategies to strengthen your position. — 2026-03-16, updated 2026-08-21 - [KPO Knjiga Demystified: How to Track Revenue Correctly](https://preduzmi.com/articles/kpo-book): Everything you need to know about Serbia's KPO book for paušal entrepreneurs: what goes in, what doesn't, foreign currency conversion, paper vs electronic format, and the 7 most common mistakes. — 2026-03-16, updated 2026-08-21 - [6 Million vs 8 Million: The Complete Guide to Serbian Paušal Revenue Limits](https://preduzmi.com/articles/revenue-limits): Understand the two revenue thresholds for Serbian paušal entrepreneurs: the 6M calendar-year limit and the 8M rolling 12-month PDV limit. Learn how each is calculated and what happens if you exceed them. — 2026-03-16, updated 2026-08-21 - [How to Pay Your Paušal Taxes: 4 Payments, 4 Accounts, and Reference Numbers](https://preduzmi.com/articles/tax-payments): Step-by-step guide to making monthly paušal tax payments in Serbia: treasury accounts, BOP reference numbers, payment codes, and how to fix errors. — 2026-03-16, updated 2026-08-21 # How to Read a Serbian Paušal Tax Decision: Fields, Deadlines, Appeals Source: https://preduzmi.com/articles/pausal-tax-decision Published: 2026-08-19, updated 2026-08-21 > A field-by-field guide to the annual tax decision (rešenje) for Serbian paušalci: where it is delivered, what the assessed base and the BOP mean, why the amount rose, and the 15-day appeal clock that starts the day it is posted. *Last updated: August 2026. Reflects the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", with amendments consolidated through br. 6/2026), the [Zakon o doprinosima za obavezno socijalno osiguranje](https://www.paragraf.rs/propisi/zakon_o_doprinosima_za_obavezno_socijalno_osiguranje.html), the [Zakon o poreskom postupku i poreskoj administraciji](https://www.paragraf.rs/propisi/zakon_o_poreskom_postupku_i_poreskoj_administraciji.html), and the* Uredba o bližim uslovima, kriterijumima i elementima za paušalno oporezivanje *("Sl. glasnik RS", br. 94/2019 … 115/2025).* **In short** - **What it is:** one annual decision from the Poreska uprava that fixes your *paušalno utvrđen prihod* and your four monthly obligations for the whole year. - **Where it goes:** into the tax mailbox (*poresko sanduče*) on the ePorezi portal. Not by email, not on paper. - **When it arrives:** **no statutory deadline exists.** For 2026, delivery began **19 January 2026** and the first advance was due **18 February 2026**. - **The trap:** a rešenje is **deemed served the day it is posted to the portal** (ZPPPA čl. 36). The **15-day** appeal clock runs whether or not you logged in. - **What is on it:** the base, four obligations at a combined **45.05%**, four treasury accounts, and the **BOP** — your unique payment reference. - **If it is wrong:** a return by **31 January** fixes the base going forward (ZPDG čl. 93 st. 2); an appeal within **15 days** attacks the decision itself (ZPPPA čl. 142, 143). Neither one pauses your monthly payments (ZPPPA čl. 147 st. 1). --- ## What the rešenje actually decides The annual *rešenje* determines every payment you make for twelve months. It states one number — your *paušalno utvrđen prihod* — and derives four monthly obligations from it. Nothing else you do during the year changes those amounts. That base is the tax base for income tax (ZPDG čl. 33 st. 1 i st. 3) **and** the contribution base for social insurance (ZDOSO čl. 22 st. 3). One figure, two uses. A new rešenje each January is **not** an annual re-approval of your paušal status. Under ZPDG čl. 42 st. 4 that status runs indefinitely, until it is established that the conditions for it have ceased. The yearly decision only re-prices it. --- ## When it arrives, and why no date is guaranteed **No statutory deadline was found governing when the Poreska uprava must issue the annual rešenje.** Not in the ZPDG, not in the Uredba. Anyone who tells you it "must" arrive by a fixed date is describing a habit, not a rule. What is documented is one year's practice. The Tax Administration announced that delivery of the 2026 decisions, together with a report on the method used to determine the lump-sum income, began on **19 January 2026** and continued in the days that followed. The **first 2026 advance instalment was due 18 February 2026**, moved from 15 February because of public holidays. Treat mid-to-late January as the expected window and nothing more. Note the second document in that announcement. **Alongside the rešenje, the Poreska uprava delivers a report on how the lump-sum income was determined** — the working behind the number. Most paušalci open the decision and never look at it. --- ## Where to find it: the tax mailbox on ePorezi **The rešenje is delivered electronically, by being posted into your tax mailbox — the *poresko sanduče* — on the ePorezi portal at `eporezi.purs.gov.rs`.** It is not emailed to you, and it is not mailed to your registered seat. You reach it with the same credentials you already use to file electronically: a qualified electronic certificate or an eID login. The mailbox is a section of the portal, not a notification — nothing pings your phone when a document lands in it. One wrinkle explains most "it never arrived" reports. If an accountant or another authorised person holds the ePorezi authorisation for your PIB, the decision is delivered where **they** can see it. It was served on you all the same. **Electronic posting is legal service. The appeal clock starts then.** Under **ZPPPA čl. 36**, a tax act *"smatra se dostavljenim danom postavljanja na portal Poreske uprave"* — it is deemed served on the day it is posted to the Tax Administration portal. **ZPPPA čl. 36** adds that **no separate consent is required** from a natural person who already files tax returns electronically. The practical consequence is severe and almost never published: the **15-day** appeal period under ZPPPA čl. 142 begins on the day of posting, **not** on the day you first open the portal. A paušalac who checks the mailbox in March has lost the appeal on a January decision without ever having seen it. --- ## The document, field by field **Every paušal rešenje carries the same nine elements: the assessed base, the four monthly obligations, the treasury accounts, the BOP, the payment deadline and the appeal instruction.** Layout varies between tax offices and between years, and the labels on your copy may be worded differently. The substance below is what every rešenje has to carry. | Field | What it means | What you do with it | |---|---|---| | **Paušalno utvrđen prihod** | The assessed income the whole decision rests on. It is **not** your real revenue. | Check it against the derivation before anything else. See [how the base is calculated](/articles/pausal-tax-base). | | **Porez na prihode od samostalne delatnosti** | Income tax at **10%** of the base (ZPDG čl. 38). | Pay monthly, to its own account. | | **Doprinos za PIO** | Pension and disability contribution at **24%** (ZDOSO čl. 44 st. 1 t. 1). Always the largest line. | Pay monthly, separate transfer. | | **Doprinos za zdravstveno osiguranje** | Health contribution at **10.3%** (ZDOSO čl. 44 st. 1 t. 2). | Pay monthly, separate transfer. | | **Doprinos za osiguranje za slučaj nezaposlenosti** | Unemployment contribution at **0.75%** (ZDOSO čl. 44 st. 1 t. 3). The smallest line. | Pay monthly, separate transfer. | | **Uplatni računi** | One treasury account per obligation, each under the **840-** prefix. | Copy them exactly. Details in [the guide to paying your paušal taxes](/articles/tax-payments). | | **BOP** — *broj odobrenja za plaćanje* | Your unique payment approval number. It routes each transfer to your tax account. | Goes in the *poziv na broj* field, under model **97**. | | **Rok plaćanja** | **Within 15 days of the end of each month** (ZPDG čl. 110 t. 1). ZDOSO čl. 60 st. 1 applies the same deadline to contributions. | Twelve payment dates, all year. | | **Appeal instruction** | The paragraph telling you where and by when to contest the decision. | **15 days** from receipt of the act (ZPPPA čl. 142). | The four rates add up to **45.05%** of the assessed base — 35.05% in contributions plus 10% income tax. If the four monthly lines on your rešenje do not sum to 45.05% of the monthly base, something on the document needs explaining. There is **no tax-free allowance**. A paušalac owes the full assessed amount in a month with zero revenue exactly as in a month with a full order book (ZPDG čl. 38; ZDOSO čl. 22 st. 3). --- ## The payment block: model 97 and the BOP Everything you need to pay is printed on the rešenje. The bank form takes five fields. | Field on the payment form | What goes in it | Source | |---|---|---| | **Račun primaoca** | The treasury account for that specific obligation, under the **840-** prefix | The rešenje | | **Model** | **97** | The rešenje's payment instructions | | **Poziv na broj** | Your **BOP** | The rešenje | | **Šifra plaćanja** | **253** from e-banking, **153** at a counter | Payment code convention | | **Iznos** | The monthly amount for that obligation | The rešenje | The BOP is the piece that goes wrong. It is your identity inside the treasury's accounting, and a wrong or last-year's BOP does not bounce: the money leaves your account, reaches the Treasury, and sits unallocated against nobody's obligation. The obligation itself stays open and accrues interest at the NBS reference rate plus 10 percentage points (ZPPPA čl. 75 st. 1–4) — see [what a late paušal payment costs](/articles/late-payment-interest). **Verify every payment field yourself** The account numbers, the BOP and the amounts on **your** rešenje are the authoritative ones. This guide describes the procedure; it does not confirm anyone's individual details. Check each field against your own decision and against your bank's form before you send the first transfer of the year, and replace last year's saved bank templates rather than editing the amounts in them. --- ## Where the number on your rešenje comes from The base is not a percentage of the average salary, and it is not arbitrary. You are grouped by *pretežna delatnost* (ZPDG čl. 41 st. 1–2), and Uredba čl. 4 st. 2 then sets a *polazna osnovica*: the average monthly salary in the relevant city or *opština* over the last twelve months, multiplied by the number of employees there and by the **koeficijent delatnosti** for your activity code, divided by the population there. Two rules change the outcome. For the codes listed in Uredba čl. 4 st. 4 — which include **6201** and **6202**, the two most common IT codes — the **Republic-level** figures are used instead of local ones, so **your municipality does not affect the base at all**. Then Uredba čl. 5 applies a ladder of coefficients: registration age, the taxpayer's own age, disability, extended parental absence, certified old crafts, and a zone multiplier that reaches only a short listed set of codes. Their cumulative product cannot fall below 0.5 (Uredba čl. 5 st. 2–3). The full derivation is in [the guide to the paušal tax base](/articles/pausal-tax-base). It is the only way to tell whether the number you were sent is the number the formula produces. **The minimum contribution base does not apply to you** For 2026 the *najniža* monthly contribution base is **51,297 RSD** and the *najviša* is **732,820 RSD**. Neither applies to a paušalac: ZDOSO čl. 22 st. 3 makes the *paušalno utvrđen prihod* itself the contribution base. Comparing your rešenje against the published minimum is the most common false alarm in the January inbox. --- ## Why the amount went up **Most increases are the transition cap doing its job.** Uredba čl. 6 st. 1 caps the annual increase at **10% per year until the correct level is reached, through 2027**. A base sitting below its formula value therefore climbs in yearly steps rather than in one jump, and a roughly 10% rise on an otherwise unchanged business is the expected shape of that. **The cap has an exception.** Under Uredba čl. 6 st. 2 the 10% limit does **not** apply where the increase results from a change of activity code, of municipality, or of business location. Move your *sedište*, or change your *pretežna delatnost*, and the new base can arrive in full in a single year. If your amount rose by far more than a tenth and nothing about your registration changed, check it against the derivation rather than absorbing it. --- ## If the base is wrong: two different remedies These are separate instruments with separate deadlines, and people routinely reach for the wrong one. | | Return under ZPDG čl. 93 st. 2 | Appeal under ZPPPA čl. 142–143 | |---|---|---| | **What it is for** | A significant change in the scope or turnover of the business in the preceding year | A defect in the decision itself | | **Deadline** | **31 January** of the assessment year | **15 days** from receipt of the act (ZPPPA čl. 142) | | **Filed with** | Poreska uprava | Addressed to the second-instance body, but handed in to the first-instance tax office that issued the decision (ZPPPA čl. 143 st. 1) | | **Burden of proof** | The taxpayer states the changed circumstances | **On the appellant** (ZPPPA čl. 143 st. 4) | | **Effect** | Corrects the base **going forward** | Attacks the existing decision — but does **not** suspend payment (ZPPPA čl. 147 st. 1) | A change of *pretežna delatnost* has its own timing: the return is due by **31 January of the year following the change**, and Uredba čl. 3 st. 3–5 makes lateness concrete — filed on time, the change applies from the next tax period; filed late, the Poreska uprava may apply it retroactively from the first day of the period in which the change occurred. **An appeal does not buy you time to pay.** ZPPPA čl. 147 st. 1 reads *"Žalba ne odlaže izvršenje poreskog upravnog akta."* The monthly obligations stay due and interest keeps running while the *žalba* is pending. Only the second-instance body can postpone execution, and only where you document that paying before the act becomes final would cause substantial economic harm (čl. 147 st. 2). That same body must decide the appeal within **60 days** (čl. 147 st. 4). On the appeal fee: an administrative *taksa* applies, but the amounts in the *Zakon o republičkim administrativnim taksama* have been revised and the figures circulating on Serbian blogs are out of date. **Confirm the current amount with the Poreska uprava before you file.** Neither route is a substitute for professional advice where a disputed activity classification or real money is involved. Preduzmi tracks what you owe and when; it does not argue your case. --- ## If you are sure it never arrived Work through this before concluding anything. 1. **Log into ePorezi and open the tax mailbox.** In the overwhelming majority of cases the decision is there, unread, from January. 2. **Check who holds your portal authorisation.** If your accountant is the authorised person for your PIB, the document was delivered to their view of the mailbox. It is still served on you. 3. **Confirm your registration details are current at APR.** A stale seat or contact record is the ordinary cause of a genuinely missing document. 4. **Contact the Poreska uprava branch for your registered seat** if the mailbox is genuinely empty. While you look, remember what does not pause. The monthly deadline in ZPDG čl. 110 t. 1 runs regardless of whether you have read the decision, and so does the 15-day appeal period. An unopened document is a served document. The month-by-month view of the rest of the year is in [the compliance calendar](/articles/calendar-checklist). --- ## Not to be confused: the eko taksa rešenje **The local environmental fee arrives on a different document, from a different authority, with a different reference number.** Your paušal rešenje comes from the Poreska uprava and covers republic-level tax and contributions. The eko taksa rešenje comes from your *lokalna poreska administracija*, and it typically stays valid across years instead of being reissued each January. Paying one obligation against the other document's reference number leaves both unsettled. The eko taksa rules are in [the eko taksa guide](/articles/eko-taksa). --- ## Key takeaways 1. **The rešenje fixes one number — the *paušalno utvrđen prihod* — and everything else on the document is derived from it** at a combined 45.05% (ZPDG čl. 38; ZDOSO čl. 44 st. 1). 2. **It is deemed served the day it is posted to the ePorezi portal** (ZPPPA čl. 36), so the 15-day appeal period can expire before you ever open the mailbox. 3. **No statutory deadline governs when the Poreska uprava issues it**; the 2026 decisions began arriving on 19 January 2026, but that is an observed date, not a rule. 4. **The BOP is your payment identity**, entered as the *poziv na broj* under model 97 — and a wrong one strands the money without ever returning it to you. 5. **Payments are due within 15 days of the end of each month** (ZPDG čl. 110 t. 1), in full, even in a month with no revenue. 6. **An increase of about 10% is the transition cap** (Uredba čl. 6 st. 1); a much larger one usually traces to a change of activity code, municipality or location, which the cap does not cover (Uredba čl. 6 st. 2). 7. **Two remedies, two clocks:** a return by 31 January corrects the base going forward (ZPDG čl. 93 st. 2), an appeal within 15 days attacks the decision itself (ZPPPA čl. 142, 143) — and neither one suspends the monthly payments while it runs (ZPPPA čl. 147 st. 1). --- ## Frequently asked questions ### When does a Serbian paušalac receive the annual poresko rešenje? No statutory deadline governs when the Poreska uprava must issue the annual rešenje, so there is no date you can rely on. In practice it arrives early in the year: the Tax Administration announced that delivery of the 2026 decisions began on 19 January 2026 and continued in the days that followed, with the first advance instalment due on 18 February 2026. That is an observed date for one year, not a rule, so treat it as a guide rather than a promise. ### Where is the poresko rešenje delivered for a Serbian paušalac? It is delivered electronically, by being posted into the taxpayer's tax mailbox (poresko sanduče) on the ePorezi portal at eporezi.purs.gov.rs. It does not arrive by email and it is not sent on paper. If an accountant or another authorised person holds your ePorezi authorisation, the document lands where they can see it, which is why many paušalci believe nothing was ever sent. ### Is a Serbian tax rešenje considered delivered if the paušalac never opened the ePorezi portal? Yes. Under ZPPPA čl. 36 a tax act is deemed served on the day it is posted to the Tax Administration portal, and the same article removes the need for separate consent from anyone who already files tax returns electronically. The 15-day appeal period therefore starts running on the day of posting, whether or not you ever logged in. Checking the mailbox is not optional housekeeping; it is what keeps the remedy available. ### What is the BOP on a Serbian paušal tax rešenje? BOP stands for broj odobrenja za plaćanje, the payment approval number printed on your rešenje. It is the unique reference that routes each transfer to your own tax account, and it goes on the payment form as the poziv na broj under model 97. A wrong or outdated BOP does not bounce the payment back: the money leaves your account and sits unallocated until the tax office reassigns it. Copy it from the current rešenje rather than from last year's saved template. ### What is the deadline to appeal a rešenje on paušal tax in Serbia? Fifteen days from receipt of the tax administrative act, under ZPPPA čl. 142. The appeal is handed in to the first-instance tax office that issued the decision, and the burden of proving the claim rests on the appellant (ZPPPA čl. 143). Because electronic delivery counts as receipt on the day of posting, those fifteen days can already be running before you have read the document. Lodging an appeal does not suspend payment either: under ZPPPA čl. 147 st. 1 the obligation stays due while the appeal is decided. ### Why did the paušal tax amount on a Serbian entrepreneur's rešenje increase this year? Most often because the assessed base is still catching up to its correct level. Uredba čl. 6 st. 1 caps annual increases at 10 percent per year until that level is reached, through 2027, so a base that is below it can rise by up to a tenth each year. That cap does not apply where the increase follows a change of activity code, municipality or business location, under Uredba čl. 6 st. 2, which is why those changes can produce a much larger jump in one step. ### What should a Serbian paušalac do if the poresko rešenje never arrived? Log into ePorezi and open the tax mailbox before doing anything else, because the decision is almost always sitting there. Then check whether an accountant or another authorised person holds the portal authorisation for your PIB, since the document may be visible only to them. If the mailbox is genuinely empty, contact the Poreska uprava branch for your registered seat. A document you have not read suspends nothing: the monthly deadline in ZPDG čl. 110 t. 1 runs regardless, and so does the appeal period. ### Does the minimum monthly contribution base apply to a Serbian paušalac? No. The contribution base for a paušalac is the paušalno utvrđen prihod set by the rešenje, under ZDOSO čl. 22 st. 3. The najniža and najviša monthly contribution bases published for 2026, 51,297 RSD and 732,820 RSD, apply to other categories of insured persons and not to a paušalac's assessed base. Comparing your rešenje against the minimum base is a common source of false alarm. ### How can a Serbian paušalac correct a wrong base on the paušal tax rešenje? There are two separate routes and they do different things. If the scope or turnover of the business changed significantly in the preceding year, ZPDG čl. 93 st. 2 requires a tax return by 31 January of the assessment year, and that corrects the base going forward. If the decision itself is defective, the remedy is an appeal within 15 days of receipt under ZPPPA čl. 142 and čl. 143. The two deadlines are independent, and missing the January return does not extend the appeal period. ### Is the eko taksa rešenje the same document as the paušal tax rešenje in Serbia? No. The paušal tax rešenje comes from the Poreska uprava and sets your republic-level income tax and social contributions. The eko taksa rešenje comes from your local tax administration, carries its own reference number, and typically stays valid across years instead of being reissued every January. Paying one obligation against the other document's reference number leaves both of them unsettled. --- ## Sources - [Zakon o porezu na dohodak građana (ZPDG)](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) — "Sl. glasnik RS", with amendments consolidated through br. 6/2026. Articles cited: 33, 38, 41, 42, 93, 110. - [Zakon o doprinosima za obavezno socijalno osiguranje (ZDOSO)](https://www.paragraf.rs/propisi/zakon_o_doprinosima_za_obavezno_socijalno_osiguranje.html) — articles cited: 22, 44, 60. - [Zakon o poreskom postupku i poreskoj administraciji (ZPPPA)](https://www.paragraf.rs/propisi/zakon_o_poreskom_postupku_i_poreskoj_administraciji.html) — articles cited: čl. 36 (electronic service), čl. 75 (interest), čl. 142 and čl. 143 (appeal), čl. 147 (an appeal does not suspend execution). - [Poreska uprava — Preduzetnici paušalci](https://www.purs.gov.rs/preduzetnici-pausalci.html), which publishes the *Uredba o bližim uslovima, kriterijumima i elementima za paušalno oporezivanje* ("Sl. glasnik RS", br. 94/2019 … 115/2025) and the official paušal calculator. - [Poreska uprava announcement on the 2026 tax decisions](https://purs.gov.rs/en/Bureau-for-Information/News/4608477/) — delivery from 19 January 2026 into the ePorezi tax mailbox; first advance due 18 February 2026. - [ePorezi portal](https://eporezi.purs.gov.rs/) — the tax mailbox where the rešenje is served. - [Republički fond za PIO — osnovice za uplatu doprinosa](https://www.pio.rs/sr/osnovice-za-uplatu-doprinosa) — the 2026 najniža and najviša monthly contribution bases. # Mirovanje vs Brisanje: Pausing or Closing a Serbian Paušal Business Source: https://preduzmi.com/articles/mirovanje-vs-brisanje Published: 2026-08-12, updated 2026-08-21 > Mirovanje suspends your contributions under ZDOSO čl. 50; brisanje ends the business permanently. What each costs at APR in 2026, which documents you need, and the traps in both procedures. *Last updated: August 2026. This guide reflects the [Zakon o privrednim društvima](https://www.paragraf.rs/propisi/zakon-o-privrednim-drustvima.html) ("Sl. glasnik RS", br. 36/2011 … 109/2021), the [Zakon o doprinosima za obavezno socijalno osiguranje](https://www.paragraf.rs/propisi/zakon_o_doprinosima_za_obavezno_socijalno_osiguranje.html), the [Zakon o porezu na dohodak građana](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2001/80/7/reg) (consolidated through "Sl. glasnik RS", br. 6/2026), and APR's Odluka o naknadama ("Sl. glasnik RS", br. 95/2025), applicable from 1 January 2026.* **In short** - **Contributions stop during a registered prekid.** ZDOSO čl. 50: *"obaveza plaćanja doprinosa **miruje** u periodu u kojem ne obavlja delatnost"* — with an express right to keep paying voluntarily. - **Pausing costs 1,400 RSD at APR**, filed as a *registracija promene podataka*. **Brisanje also costs 1,400 RSD.** Both from the Odluka o naknadama ("Sl. glasnik RS", br. 95/2025), čl. 8 i 9, in force from 1 January 2026. - **A prekid needs no tax clearance certificate.** Brisanje needs **two**, each no more than **5 days old**. - **Neither can be backdated** — ZPD čl. 90 for the prekid, ZPD čl. 91 for the deletion. - **A paušalac files no 30-day tax return on either a prekid or a closure.** ZPDG čl. 94 st. 3 imposes that return on an obligor who *prestane, odnosno prekine* the activity — but addresses it to obligors *"osim preduzetnika paušalca"*. - **No maximum duration for a prekid was found in ZPD čl. 90**, and no limit on repetitions. The widely republished "two years" cap is not in the text of that article. --- ## Pause or close: the decision in one table The practical difference is reversibility. A **prekid** leaves your APR registration, PIB, KPO knjiga and business bank account exactly where they are; **brisanje** removes you from the register and cannot be undone. | | Mirovanje (*registrovani prekid*) | Brisanje (deletion) | |---|---|---| | **What it does** | Suspends the activity, keeps the registration | Ends the entrepreneur status | | **APR fee (from 1.1.2026)** | **1,400 RSD** | **1,400 RSD** | | **What you file** | *Registraciona prijava promene podataka* + **Dodatak 06** | Deletion application + fee proof + two clearance certificates | | **Tax clearance certificate** | **Not required** | **Required** — PU + local tax administration, max 5 days old | | **Social contributions** | **Suspended** (ZDOSO čl. 50); voluntary payment allowed | End with the business, once settled | | **PIB, KPO knjiga, business account** | Kept | Closed with the business | | **Eko taksa** | No fee for the period (čl. 138a st. 1 t. 2); filing duty remains | Ends; status change filed within 15 days | | **Retroactive effect** | Not possible (ZPD čl. 90) | Not possible (ZPD čl. 91) | | **APR decision time** | **5 radnih dana** | **5 radnih dana** | | **Reversible** | Yes — register the resumption | No — starting again is a new registration, 2,500 RSD | Pausing and closing cost the same at the counter. The difference appears only if you later want to trade again: a new *preduzetnik* registration is a fresh 2,500 RSD filing under the same Odluka o naknadama. --- ## Mirovanje: what a registered prekid actually stops **A registered prekid suspends the obligation to pay social contributions.** ZDOSO čl. 50 st. 1 reads: *"Preduzetniku koji prekine obavljanje delatnosti u skladu sa zakonom, obaveza plaćanja doprinosa miruje u periodu u kojem ne obavlja delatnost."* Stav 2 of the same article adds the option to continue: *"Preduzetnik iz stava 1. ovog člana može nastaviti plaćanje doprinosa i u periodu u kojem ne obavlja delatnost."* You do not have to close the business to stop the monthly PIO, health and unemployment contributions. **No 30-day tax return falls due on a prekid either.** ZPDG čl. 94 st. 3 puts that return on an obligor who ceases *or interrupts* the activity, and then excludes paušalci by name — *"osim preduzetnika paušalca"*. Two qualifications matter. First, the suspension attaches to the **registered** prekid, not to the fact that you stopped working — quietly not invoicing changes nothing about your obligations. Second, the voluntary continuation in stav 2 exists for a reason: contributions are what keep pension *staž* and health cover running, and the trade-off is set out in [health insurance and pension for paušalci](/articles/health-pension). **The tax line is not covered by the same article** ZDOSO čl. 50 suspends *doprinosi*. **No equivalent express provision for *porez na prihode od samostalne delatnosti* was located in ZPDG.** Treat the tax line of your *rešenje* as live until Poreska uprava says otherwise, and confirm your monthly obligations with PU once APR has registered the prekid. That is practice, not a statutory rule — we found no rule either way. What the pause touches, and what it leaves alone: | Obligation | During a registered prekid | |---|---| | PIO, health, unemployment contributions | **Suspended** — ZDOSO čl. 50; voluntary payment expressly allowed | | Porez na prihode od samostalne delatnosti | No express suspension found in ZPDG — verify your *rešenje* with PU | | Eko taksa fee | **Not charged** for the period — Zakon o naknadama čl. 138a st. 1 t. 2 | | Eko taksa filing | Still owed; the status change is filed within **15 days** — čl. 138 st. 3 | | KPO knjiga | Stays. Retention is **at least 5 years** from the last day of the business year — ZPDG čl. 48 | | Business bank account | Stays open — a prekid does not close it | | APR registration and PIB | Both remain | A prekid does not retire the KPO knjiga: it stays part of your records, and the retention clock in ZPDG čl. 48 runs regardless. See [the KPO knjiga guide](/articles/kpo-book) for what the format has to preserve. --- ## Registering a prekid with APR A prekid is filed as an ordinary change of registered data. The steps, in order: 1. **Post the notice.** ZPD čl. 90 obliges the entrepreneur to display a notice about the period of suspension at the place where the activity is performed. 2. **File the *registraciona prijava promene podataka*** with APR, together with **Dodatak 06** — the annex used for a temporary suspension. 3. **Pay 1,400 RSD.** This is the standard *promena podataka* fee (Odluka o naknadama, "Sl. glasnik RS", br. 95/2025, čl. 8 i 9). Additional changes bundled into the same application are charged 700 RSD each. 4. **Wait up to 5 radnih dana** for the registrar's decision. That deadline binds APR, not you — there is no statutory deadline by which you must register a change. 5. **File the eko taksa status change within 15 days** with your local tax administration (čl. 138 st. 3). See [eko taksa](/articles/eko-taksa) for the form and the office. **No tax clearance certificate is needed for a prekid** — that requirement belongs to brisanje only. And the start date cannot be moved backwards: ZPD čl. 90 states that a prekid *"se registruje u skladu sa zakonom o registraciji i ne može se utvrđivati retroaktivno"*. If you stopped working in March and file in July, the months in between were active months. One blocking condition: **APR cannot register changes while a tax audit is in progress or while the PIB is temporarily revoked** (ZPPPA čl. 29). If you are mid-audit, the prekid waits. --- ## Duration and repetition of a prekid **ZPD čl. 90 sets no maximum duration for a prekid and no limit on how many times it may be repeated.** The article contains two obligations only — post the notice, register the suspension — and one prohibition, that it cannot be established retroactively. A "two-year maximum" is republished across Serbian and Russian-language sites. That cap does not appear in the text of ZPD čl. 90, and it was not located elsewhere during this research — but "not found" is not the same as "verified as absent". If you are planning a multi-year pause, put the question to APR first. A different two-year rule does exist, and the two get confused. Under **ZPD čl. 91 st. 6 t. 3**, an entrepreneur ceases to perform the activity *po sili zakona* if the business account has been **blocked continuously for more than two years**, on an initiative to start the deletion procedure filed by the Narodna banka Srbije or the Poreska uprava. The registrar then publishes a notice on the register's website, gives **90 days** to unblock the account or remove the cause (st. 7), and after a further **30 days** deletes the entrepreneur ex officio (st. 8). That is the real risk of the informal pause — walking away without registering anything, letting obligations accrue, and having the register close the business for you on someone else's timetable. --- ## Brisanje: closing the business for good **The order of steps is what people get wrong: tax clearance first, APR second.** The registrar does **not** obtain the certificates ex officio, so a deletion application filed without them goes nowhere. APR requires, for the deletion of an entrepreneur: | Document | Detail | |---|---| | Deletion application | The registration form for *brisanje preduzetnika* | | Proof of fee payment | **1,400 RSD** — Odluka o naknadama ("Sl. glasnik RS", br. 95/2025), čl. 8 i 9 | | Poreska uprava certificate | No outstanding *porez na prihode od samostalne delatnosti* and PIO contributions. **Max 5 days old** | | Local tax administration certificate | The same confirmation from your LPA. **Max 5 days old** | | VAT deregistration | Checked **ex officio** by the registrar; a precondition, not an attachment | **No separate statutory deadline governing the final settlement of paušal dues on closure was located in ZPDG.** The operative constraint is the certificates: both expire five days after issue, so the clearance, the notary step (if you file electronically) and the APR filing all have to fit inside one short window. Deletion also cannot reach backwards. ZPD čl. 91 is explicit on both halves of this: *"Preduzetnik odjavu ne može izvršiti sa danom koji je raniji od dana podnošenja prijave o prestanku rada nadležnom registracionom organu"*, and *"Brisanje iz registra se ne može vršiti retroaktivno."* **The electronic-filing trap** The Poreska uprava certificate is issued **on paper only**. For an electronic application it must be **digitalised by a notary, or by an attorney who is also the applicant**. If you scan and digitalise it yourself, **the application is rejected** — and by then the five-day validity of the certificate is likely gone, so you start again with a fresh one. It appears in almost no consumer-facing content. --- ## What a paušalac does not have to file when closing **A paušalac files no final tax return on cessation of activity.** ZPDG čl. 94 st. 3 prescribes the 30-day return for an obligor who *prestane, odnosno prekine* the activity — cessation and suspension alike — but only for obligors *"osim preduzetnika paušalca"*. That is, for *knjigaši*, not for you. The claim that every closing entrepreneur owes a 30-day final return is one of the most repeated errors on this topic. **A paušalac also files no *vanredni finansijski izveštaj*.** That obligation applies only to entrepreneurs who keep business books. A paušalac keeps only the KPO knjiga, so there is no financial statement to submit. What you do owe is settlement. Every monthly obligation up to the cessation date must be paid before the certificates can be issued, so reconciling your *stanje na kartici* in ePorezi against your own payment record — see [monthly tax payments](/articles/tax-payments) — is the first move, not the last. --- ## What survives the deletion Two things outlive the business. **Your records.** ZPDG čl. 48 requires books and records to be kept **at least 5 years** from the last day of the business year they relate to. Deletion from the register does not shorten that. Keep the KPO knjiga, the invoices and the *rešenja* for the full period. **Two liability rules sit in ZPDG čl. 157, and they are not the same rule** **ZPDG čl. 157 st. 2** makes **all adult members of the entrepreneur's household subsidiarily liable, with their own property, for the *porez na prihode od samostalne delatnosti***. The household is the one that existed at the moment the obligation arose, as defined in ZPDG čl. 10. *Subsidiarily* means the tax authority reaches them only where the obligation cannot be collected from the entrepreneur. **ZPDG čl. 157 st. 3** is the closure rule: an entrepreneur who ceases the activity must settle every tax obligation arising from it **before deletion from the register**. The same stav makes anyone who takes over the business assets, with or without payment, **jointly and severally** liable for those obligations, up to the value of what was taken over. Both are stated here without drama, because they are stated almost nowhere else: an unreconciled tax account does not disappear when the register entry does. --- ## Eko taksa in both procedures **The eko taksa fee is not charged for the duration of a registered prekid** — Zakon o naknadama čl. 138a st. 1 t. 2 — **but the filing obligation remains**. Under čl. 138 st. 3, a change of status, including the start of a registered prekid and the cessation of the business, is filed with the local tax administration **within 15 days** of registering the change. This is where old debts surface. An LPA that never received the change filings keeps assessing the fee, and the arrears appear exactly when you need a clean local-tax certificate to close. Full procedure: [the eko taksa guide](/articles/eko-taksa). Annual dates: the [compliance calendar](/articles/calendar-checklist). --- ## The maternity timing trap **Contact RFZO before filing a prekid where a maternity benefit is intended.** APR states this explicitly in its own guidance, because the start date you register determines how the benefit is calculated — and, per ZPD čl. 90, it is the one thing that cannot be corrected afterwards. The general rules for maternity and sick-leave entitlements are in [health insurance and pension for paušalci](/articles/health-pension). The timing question belongs to RFZO, before the APR filing. --- ## Key takeaways 1. **A registered prekid suspends social contributions** under ZDOSO čl. 50, with an express option to keep paying voluntarily. Closing is not the only way to stop the monthly contributions. 2. **Both procedures cost 1,400 RSD at APR** from 1 January 2026; a fresh registration afterwards costs 2,500 RSD. Figures of 850, 750 or 1,600 RSD circulating online are pre-2026. 3. **A prekid needs no tax clearance; brisanje needs two certificates, each no more than 5 days old**, and the registrar does not obtain them for you. 4. **Neither a prekid nor a deletion can be backdated** — ZPD čl. 90 and čl. 91 both say so in terms. 5. **Filing brisanje electronically requires a notary** (or an attorney who is the applicant) to digitalise the paper PU certificate; self-digitalisation gets the application rejected. 6. **A paušalac owes no final tax return and no vanredni finansijski izveštaj** on closure — ZPDG čl. 94 st. 3 excludes paušalci from the 30-day return. 7. **Settle everything before deletion:** ZPDG čl. 157 st. 3 requires every tax obligation to be met before the register entry goes, and čl. 157 st. 2 makes adult household members subsidiarily liable with their own property for the *porez na prihode od samostalne delatnosti*. Preduzmi tracks which obligations stay live through a pause and which fall away, so your calendar reflects your actual status. It does not replace an accountant or a lawyer where a closure is contested, a tax audit is open, or a benefit entitlement turns on the exact start date. --- ## Frequently asked questions ### Does a Serbian paušalac pay contributions during mirovanje? No. Under ZDOSO čl. 50, the obligation to pay social contributions is suspended for the period in which a registered entrepreneur does not perform the activity, and the same article expressly allows the entrepreneur to keep paying voluntarily. The suspension is tied to the prekid being registered with APR, not to the fact that you stopped invoicing. Voluntary payment is the route to keeping pension staž accruing through the pause. ### How does a Serbian entrepreneur register mirovanje with APR? You file a registraciona prijava promene podataka with APR together with Dodatak 06, the annex used for a temporary suspension of activity, and pay the 1,400 RSD fee in force from 1 January 2026. No tax clearance certificate is required for a prekid. The entrepreneur must also post a notice about the suspension period at the place where the activity is performed, as required by ZPD čl. 90. APR decides within five working days. ### How long can mirovanje of a Serbian entrepreneur last? ZPD čl. 90 sets no maximum duration and no limit on how many times a prekid may be repeated; it requires only that the suspension be registered and that notice be posted at the place of business. A two-year cap is widely republished online, but it does not appear in the text of that article. Not finding a cap is not the same as proving that none exists anywhere in Serbian law, so confirm with APR before planning a very long pause. ### How much does it cost to pause or close a paušal business at APR in 2026? Registering a prekid costs 1,400 RSD, because it is filed as a registracija promene podataka, and brisanje also costs 1,400 RSD. Registering a new entrepreneur costs 2,500 RSD, which is what you would pay if you close now and start again later. These amounts come from APR's Odluka o naknadama published in Sl. glasnik RS br. 95/2025 and apply from 1 January 2026. Figures of 850, 750 or 1,600 RSD still circulating online are pre-2026 and no longer correct. ### Does a Serbian paušalac file a final tax return when closing the business? No. The 30-day return in ZPDG čl. 94 st. 3 covers an obligor who ceases or interrupts a self-employed activity, but it is addressed to obligors other than a paušalac, in the statutory wording osim preduzetnika paušalca. A paušalac is also not required to file a vanredni finansijski izveštaj, because that obligation applies only to entrepreneurs who keep business books. What must happen before deletion is settlement of the outstanding tax and contributions, which is exactly what the clearance certificates prove. ### What documents does APR require to delete a Serbian entrepreneur from the register? APR requires the deletion application, proof that the 1,400 RSD fee was paid, a Poreska uprava certificate showing no outstanding porez na prihode od samostalne delatnosti and PIO contributions, and the same kind of certificate from the local tax administration. Both certificates may be no more than five days old when the application is filed. The registrar does not obtain them ex officio, so you collect them first. Deregistration from the VAT register is checked ex officio and is a precondition. ### Can a Serbian entrepreneur file the brisanje application electronically? Yes, but there is a trap in it. The Poreska uprava certificate is issued on paper only, and for an electronic application it must be digitalised by a notary, or by an attorney who is also the applicant. If you scan and digitalise it yourself, the application is rejected. Plan the notary step into the schedule before you start the electronic filing, because the certificate is also only five days valid. ### Does a Serbian paušalac pay eko taksa during a registered prekid? No fee is charged for the duration of a registered prekid under čl. 138a st. 1 t. 2 of the Zakon o naknadama za korišćenje javnih dobara, but the filing obligation itself remains. A change of status, including the start of a registered prekid and the cessation of the business, must be filed with the local tax administration within 15 days of registering the change, under čl. 138 st. 3. Skipping that filing is the usual reason old eko taksa debts surface when someone finally tries to close the business. ### Can mirovanje or brisanje of a Serbian entrepreneur be backdated? No, in neither case. ZPD čl. 90 states that a prekid is registered under the registration law and cannot be established retroactively. For closure, ZPD čl. 91 states that an entrepreneur cannot deregister with a date earlier than the day the cessation application was filed with the registration authority, and that deletion from the register cannot be carried out retroactively. Any period before the filing date therefore still counts as an active business. ### Who is liable for a Serbian entrepreneur's unpaid taxes after brisanje? ZPDG čl. 157 st. 3 requires an entrepreneur who ceases the activity to settle every tax obligation arising from it before deletion from the register, and makes anyone who takes over the business assets jointly and severally liable for those obligations up to the value of what was taken over. Separately, ZPDG čl. 157 st. 2 makes all adult members of the entrepreneur's household subsidiarily liable with their own property for the porez na prihode od samostalne delatnosti, the household being the one that existed when the obligation arose. Subsidiary liability means the tax authority turns to them only where the obligation cannot be collected from the entrepreneur. This is the strongest practical reason to reconcile every tax account before filing for deletion rather than after. --- ## Sources - [Zakon o privrednim društvima](https://www.paragraf.rs/propisi/zakon-o-privrednim-drustvima.html) — čl. 90 (prekid obavljanja delatnosti, no retroactive registration), čl. 91 (gubitak svojstva preduzetnika, no retroactive deletion, ex officio deletion after a two-year account block). "Sl. glasnik RS", br. 36/2011, 99/2011, 83/2014 – dr. zakon, 5/2015, 44/2018, 95/2018, 91/2019 i 109/2021. - [Zakon o doprinosima za obavezno socijalno osiguranje](https://www.paragraf.rs/propisi/zakon_o_doprinosima_za_obavezno_socijalno_osiguranje.html) — čl. 50 (contribution obligation suspended during a prekid; voluntary continuation). - [Zakon o porezu na dohodak građana](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2001/80/7/reg) — čl. 48 (5-year record retention), čl. 94 st. 3 (30-day return on cessation or interruption, excluding paušalci), čl. 157 st. 2 (subsidiary liability of adult household members for the porez na prihode od samostalne delatnosti), čl. 157 st. 3 (settlement before deletion; joint liability of a transferee of the business assets). - [Zakon o naknadama za korišćenje javnih dobara](https://www.mfin.gov.rs/sr/propisi-1/zakon-o-naknadama-za-koriscenje-javnih-dobara-1) — čl. 138 st. 3 (15-day status-change filing), čl. 138a st. 1 t. 2 (no fee during a registered prekid). - [APR — registracija promena za preduzetnike](https://www.apr.gov.rs/registri/preduzetnici/uputstva/promene.2059.html) — the prijava promene podataka and Dodatak 06. - [APR — brisanje preduzetnika](https://www.apr.gov.rs/registri/preduzetnici/uputstva/brisanje.2060.html) — required documents, the 5-day certificate rule, the notarial digitalisation requirement for electronic filing. - [APR — naknade za preduzetnike](https://www.apr.gov.rs/registri/preduzetnici/naknade.2066.html) — Odluka o naknadama, "Sl. glasnik RS", br. 95/2025, applicable from 1 January 2026. # Paušalac vs Freelancer in Serbia: Model A, Model B, and the Missing Allowance Source: https://preduzmi.com/articles/pausal-vs-freelancer Published: 2026-08-04, updated 2026-08-21 > A paušalac is a registered entrepreneur; the frilenser regime is quarterly self-assessment by an unregistered individual. Compare Model A and Model B, the 110,647 RSD quarterly floor, and why a paušalac has no neoporezivi iznos. *Last updated: August 2026. Reflects the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, consolidated through br. 6/2026) and the [Zakon o doprinosima za obavezno socijalno osiguranje](https://www.paragraf.rs/propisi/zakon_o_doprinosima_za_obavezno_socijalno_osiguranje.html) ("Sl. glasnik RS", br. 84/2004, consolidated through br. 6/2026).* **In short** - **They are different legal statuses, not two settings of one system.** A paušalac is a registered *preduzetnik*; the "frilenser" regime is quarterly self-assessment by an individual who is not registered as a business. - **Model B is the 10% rate. Model A is 20%.** ZPDG čl. 86 st. 2 t. 2 grants the reduced rate precisely where the Model-B *normirani troškovi* of čl. 85 st. 5 t. 2 podtačka (2) are used; Model A sits under the standard 20% (čl. 86 st. 1, čl. 58 st. 1). Sources routinely invert this. - **Model A carries a genuine tax-free floor: 110,647 RSD per quarter** of recognised costs (ZPDG čl. 12b st. 1). Below it there is no tax and no PIO. - **A paušalac has no neoporezivi iznos at all.** The full assessed amount is due every month, including a month with zero income (ZPDG čl. 38; ZDOSO čl. 22 st. 3). - **The cadence differs.** Paušal: monthly, within 15 days of month end (ZPDG čl. 110 t. 1). Frilenser: quarterly, on form **PP OPO-K**, within 30 days of quarter end (ZPDG čl. 95 st. 7). - **The model is chosen per quarter**, not once and for all. --- ## Two legal statuses, not two settings of one regime **A paušalac is a registered entrepreneur. A "frilenser" is an individual who is not registered as a business at all.** Every other difference follows from that one. A paušalac registers a *preduzetnik* at APR, receives a PIB and a *šifra delatnosti*, and is taxed on a figure the Poreska uprava assesses in advance and delivers by *rešenje*. The freelancer regime is the opposite arrangement: no registration, no *rešenje*, and a return the person files themselves once the quarter has ended. The Poreska uprava is explicit that the word carries no legal weight. Its own freelancer portal states that *"nije definisan 'frilenser' kao zakonski pojam"* — "freelancer" is not defined as a legal concept in Serbian law. What exists is a method of taxing certain income of individuals, not a business form. So the question "should I be a paušalac or a frilenser" is not a settings question. It is a question about whether to run a registered business, with everything that attaches to one. --- ## What each regime actually taxes **A paušalac is taxed on an assessed figure. A freelancer is taxed on what actually came in.** For a paušalac, the base is the *paušalno utvrđen prihod* set in the annual *rešenje* under the ZPDG čl. 41 criteria — not your invoices. Income tax is **10%** of that base (ZPDG čl. 38). Contributions are **35.05%** of the same base — PIO 24%, health 10.3%, unemployment 0.75% (ZDOSO čl. 44 st. 1) — because the contribution base for a paušalac *is* the assessed income (ZDOSO čl. 22 st. 3). Combined: **45.05% of the assessed base**. Your real revenue enters only through the ceilings: **6,000,000 RSD** for paušal status (ZPDG čl. 40 st. 2 t. 4) and **8,000,000 RSD** for VAT registration, both covered in [revenue limits](/articles/revenue-limits). Under the freelancer regime the base is real money. You take the quarter's gross receipts, subtract a statutory cost allowance (*normirani troškovi*), and what remains is taxed. The size of that allowance — and the rate applied to the remainder — depends on which of two models you choose for that quarter. --- ## Model A and Model B: the pairing most sources get backwards **Model B is the 10% model. Model A is the 20% model.** ZPDG čl. 86 st. 2 t. 2 grants the reduced 10% rate to *ugovorena naknada* taxed by self-assessment *"za koje se normirani troškovi priznaju u skladu sa članom 85. stav 5. tačka 2) podtačka (2)"* — that is, precisely and only where the Model-B costs are used. Everything else stays on the standard 20% of čl. 86 st. 1, and the parallel rule for *autorska prava* runs the same way through čl. 58 st. 1 and st. 2. | | **Model A** | **Model B** | |---|---|---| | Normirani troškovi per quarter | **110,647 RSD** (ZPDG čl. 12b st. 1) | **66,733 RSD + 34% of quarterly gross** (čl. 12b st. 2, uplifted by čl. 85 st. 5 t. 2) | | Tax rate on the remainder | **20%** (čl. 86 st. 1; čl. 58 st. 1) | **10%** (čl. 86 st. 2 t. 2) | | Tax-free floor | **Yes** — nothing taxable below 110,647 RSD in the quarter | No floor of this kind | | Minimum PIO base | Not applied | **Applied** — 3× the *najniža mesečna osnovica* (ZDOSO čl. 28 st. 2 t. 1) | | Minimum health base | **Applied** — 3× the čl. 35b base (ZDOSO čl. 28 st. 2 t. 2) | **Applied** — same rule | | How often it is chosen | Per quarter | Per quarter | Two mechanical points that matter more than they look. **The model is chosen quarter by quarter.** Each PP OPO-K return stands on its own, so the same person can file Model A for one quarter and Model B for the next. Nothing locks you in for a year. **Where both income types arise in the same quarter, the *normirani troškovi* are recognised once on the combined total** (ZPDG čl. 12b st. 3). They are not granted twice. **The official explainer page is out of date — the calculator is not** The Poreska uprava's page at `frilenseri.purs.gov.rs/korisne-informacije/dva-modela-samooporezivanja-koji-odabrati.html` still publishes the **January 2023** figures: 96,000 RSD for Model A and 57,900 RSD for Model B. Those are superseded. The current statutory amounts are **110,647** and **66,733** RSD per quarter (ZPDG čl. 12b). The **calculator** hosted on the same domain is current: checked on 21 August 2026, it computes on 110,647 and 66,733 RSD. If you use the portal, use the calculator, and treat the explainer text as historical. This is worth checking yourself before you rely on any figure quoted from that page — including figures republished from it by accounting blogs. --- ## The contribution floors: PIO under Model B, health under both **Model B has no tax-free floor, but it does have a contribution floor — and the PIO half of that floor is written around Model B alone.** ZDOSO čl. 28 st. 2 t. 1 sets the quarterly PIO base at not less than **three times the najniža mesečna osnovica** (čl. 36), and it defines the taxpayers it reaches by the Model-B cost formula itself: gross less *"zbir normiranih troškova opredeljenih u dinarskom iznosu i 34% bruto prihoda ostvarenog u kvartalu"*. The health floor is written differently. ZDOSO čl. 28 st. 2 t. 2 sets the quarterly health base at not less than three times the base in čl. 35b **for quarterly self-assessment as such**, without distinguishing the two models. Under čl. 28 st. 3, wherever the taxable income exceeds a floor, the taxable income is the base. The *najniža mesečna osnovica* for 2026 is **51,297 RSD** — 35% of the average salary used for the year ("Sl. glasnik RS", br. 112/2025), in force from 1 January to 31 December 2026. Multiply by three and you have the quarterly PIO floor. We are deliberately not printing a derived quarterly amount here. The arithmetic is simple, but the resulting figure is not itself a published one, and the input is re-indexed. Take the number from the Poreska uprava's calculator for the quarter you are filing. The consequence is structural rather than arithmetic: **under Model B, a very small quarter still produces a PIO obligation.** Under Model A, a quarter whose gross falls under 110,647 RSD produces neither tax nor PIO. The health line is the exception on both sides — its floor in čl. 28 st. 2 t. 2 is not tied to either model. --- ## The allowance a paušalac does not have **A paušalac has no neoporezivi iznos at all.** This is the single most important practical difference between the two regimes, and almost nobody states it. The assessed base is charged in full: 10% income tax (ZPDG čl. 38) plus 35.05% contributions on the same base (ZDOSO čl. 22 st. 3; čl. 44 st. 1). There is no threshold beneath which the charge stops. A month with no invoices, no clients and no bank inflow produces exactly the same obligation as a month at full capacity, and it is due within 15 days of that month's end (ZPDG čl. 110 t. 1). A freelancer on Model A has the opposite arrangement. The first **110,647 RSD** of each quarter's gross is absorbed by recognised costs (ZPDG čl. 12b st. 1), and a quarter below that line carries no tax and no PIO. **Where paušal status does bend** Paušal has no allowance, but it does have *mirovanje* — a registered suspension of activity, during which the contribution obligation is suspended (ZDOSO čl. 50). That is a formal APR filing with a registered start date, not an automatic response to a quiet month, and it cannot be backdated. --- ## Side by side | | **Paušalac** | **Frilenser regime** | |---|---|---| | Legal status | Registered *preduzetnik* | Individual, not registered as a business | | Registration | APR, **2,500 RSD** from 1 Jan 2026 | None | | What is taxed | *Paušalno utvrđen prihod* set by *rešenje* (ZPDG čl. 41) | Actual quarterly gross minus *normirani troškovi* (čl. 12b) | | Income tax rate | **10%** (ZPDG čl. 38) | **20%** Model A · **10%** Model B (čl. 86) | | Tax-free floor | **None** (ZPDG čl. 38; ZDOSO čl. 22 st. 3) | **110,647 RSD/quarter** under Model A (čl. 12b st. 1) | | Contributions | **35.05%** of the assessed base (ZDOSO čl. 44 st. 1) | PIO 24% + health 10.3% on the taxable amount; minimum PIO base under Model B, minimum health base under both (ZDOSO čl. 28 st. 2, čl. 44 st. 1) | | Books | KPO knjiga only (ZPDG čl. 43 st. 4) | No business books | | Filing cadence | Monthly payment on a standing *rešenje* | Quarterly return, **PP OPO-K** | | Deadline | Within **15 days** of month end (ZPDG čl. 110 t. 1) | Within **30 days** of quarter end (ZPDG čl. 95 st. 7) | | Eko taksa | **Yes** — *preduzetnik* is a named obveznik; typically 5,000 RSD/yr for low-impact service codes | **No** — the obveznik list covers legal entities, entrepreneurs and branches of foreign legal entities | | Turnover ceiling | **6,000,000 RSD** (ZPDG čl. 40 st. 2 t. 4) | No paušal ceiling applies | | PIO contributions | Paid every month on the assessed base | Paid per quarter, and none at all in a Model A quarter below the floor | | Who it fits | Continuous invoicing at a stable level | Irregular, occasional or seasonal income | The KPO obligation on the paušal side is a real, ongoing one — see [the KPO knjiga guide](/articles/kpo-book). The freelancer regime has no equivalent book. The eko taksa row works the same way: the obveznik list in the *Zakon o naknadama za korišćenje javnih dobara* names *pravno lice, preduzetnik i ogranak stranog pravnog lica* (čl. 134 st. 1 t. 1), and an unregistered individual is none of those. What that fee involves for a paušalac is set out in [the eko taksa guide](/articles/eko-taksa). On the pension side, note what does *not* change: staž, base and contributions are established by the PIO Fond from CROSO and Poreska uprava records (ZPIO čl. 126 st. 3, čl. 132), not from anything you file. What differs is whether a contribution was paid for a given period at all — and in a Model A quarter under the floor, none was. --- ## Filing and deadlines **The freelancer return is PP OPO-K, filed within 30 days of the end of the quarter, with the tax payable by the same deadline** (ZPDG čl. 95 st. 7). That gives a window of 1–30 April for the first quarter, 1–30 July for the second, and 1–30 October for the third; the fourth quarter follows the same 30-day rule. **PP OPO is a different form.** It covers income where the payer is not obliged to withhold tax, and it is filed within 30 days of receiving the income rather than on a quarterly cycle. The two names differ by two characters and are confused constantly. The paušal side runs on a different clock entirely: one *rešenje* per year, then a payment every month within 15 days of the month's end (ZPDG čl. 110 t. 1). No monthly return is filed — the *rešenje* is the filing. **Verify every payment instruction against your own *rešenje* or the Poreska uprava's portal before transferring money.** Account numbers, models and *poziv na broj* formats are specific to the obligation and to you, and a payment posted against the wrong reference is a problem to unwind rather than a payment made. --- ## Choosing: predictability against a floor Frame the choice as a shape, not as an amount. **The paušal amount is fixed and does not follow your income.** It is set once a year, it is the same in your best month and your worst, and it is knowable in advance. That is an advantage when income is steady and a liability when it stops. **The freelancer amount follows income and has a floor under Model A.** A quiet quarter costs little or nothing; a strong quarter costs proportionally more. That is an advantage when work is irregular and a liability when you want a predictable annual number. Everything else on the table is a consequence of registration: APR fees, the eko taksa, the KPO knjiga, the 6,000,000 RSD ceiling and the VAT threshold on one side; none of them on the other. We are not going to tell you which regime is cheaper, and you should be sceptical of any source that does without knowing your figures. Run your own numbers through the Poreska uprava's freelancer calculator and, for the paušal side, through the official *paušalni porez* calculator or a real *rešenje*. If the two regimes land close together, that is a conversation for an accountant, not for an article. --- ## Where the independence test lands differently **The independence test is written around registered entrepreneurs.** ZPDG čl. 85 st. 1 t. 17 examines the relationship between a *preduzetnik* and each individual *nalogodavac*, and income reclassified under it is expressly excluded from the 6,000,000 RSD paušal turnover count by čl. 40 st. 5. Both rules presuppose a registered business. The full mechanism, all nine criteria and the consequences of failing five of them are covered in [the independence test guide](/articles/independence-test). Whether an equivalent reclassification reaches income declared under the freelancer regime is not something we can state. No primary source addressing it was located, and an invented answer here would be worse than none. The same applies to a question people ask constantly: **can one person be a paušalac and use the freelancer regime in the same period?** Neither the ZPDG nor the Poreska uprava's freelancer portal was found to address the combination directly, and no official *mišljenje* on the point was located. Treat it as an open question to put to the Poreska uprava, not as a settled rule in either direction. If the underlying problem is single-client concentration rather than tax mechanics, the comparison you actually want is [agency vs paušalac](/articles/agency-vs-pausalac). If it is whether the assessed base beats real bookkeeping, it is [paušalac vs knjigaš](/articles/pausalac-vs-knjigash). --- ## Key takeaways 1. **A paušalac is a registered entrepreneur and a "frilenser" is not** — the Poreska uprava confirms that *frilenser* is not a defined legal concept, so the two are different statuses rather than two settings of one system. 2. **Model B carries the 10% rate and Model A carries 20%** (ZPDG čl. 86 st. 2 t. 2; čl. 86 st. 1) — the reduced rate is tied by name to the Model-B *normirani troškovi* of čl. 85 st. 5 t. 2 podtačka (2), and published sources invert this pairing routinely. 3. **Model A recognises 110,647 RSD of costs per quarter and Model B recognises 66,733 RSD plus 34% of gross** (ZPDG čl. 12b st. 1–2), chosen quarter by quarter. 4. **A paušalac has no tax-free amount** — 10% tax plus 35.05% contributions fall on the full assessed base every month, including a month with no income (ZPDG čl. 38; ZDOSO čl. 22 st. 3). 5. **Model B has no tax-free floor but does have a PIO floor**, built as three times the *najniža mesečna osnovica* of 51,297 RSD for 2026 (ZDOSO čl. 28 st. 2 t. 1); the separate health floor in čl. 28 st. 2 t. 2 is not tied to either model. 6. **The deadlines differ: 15 days after each month for a paušalac, 30 days after each quarter on PP OPO-K for a freelancer** (ZPDG čl. 110 t. 1; čl. 95 st. 7). 7. **The official "which model" explainer on the Poreska uprava's freelancer portal still shows January 2023 figures** — use the calculator on that domain, not the explainer text. --- ## Frequently asked questions ### What is the difference between a paušalac and a frilenser in Serbia? A paušalac is a registered entrepreneur (preduzetnik) entered in the APR register and taxed on an amount the Poreska uprava assesses in advance by rešenje. The freelancer regime is quarterly self-assessment by an individual who is not registered as a business at all, filed on form PP OPO-K. They are different legal statuses carrying different obligations, not two settings of the same system. The Poreska uprava states plainly that frilenser is not defined as a legal concept in Serbian law. ### Is Model A or Model B the 10 percent tax rate for Serbian freelancers? Model B carries the 10 percent rate and Model A carries 20 percent. ZPDG čl. 86 st. 2 t. 2 grants the reduced 10 percent rate only to income for which the normirani troškovi are recognised under čl. 85 st. 5 t. 2 podtačka (2), which is the Model B formula, while Model A falls under the standard 20 percent rate in čl. 86 st. 1 and čl. 58 st. 1. Many published sources invert this pairing or claim both models are taxed at 20 percent, and that is wrong. ### Does a Serbian paušalac have a neoporezivi iznos or tax-free allowance? No. A paušalac has no tax-free amount of any kind. Income tax of 10 percent under ZPDG čl. 38 and contributions of 35.05 percent under ZDOSO čl. 44 st. 1 are charged on the full assessed base, because the contribution base for a paušalac is that same assessed income under ZDOSO čl. 22 st. 3. The obligation falls due every month, including a month in which no invoice was issued and no money came in. ### How much are the normirani troškovi under Model A and Model B in Serbia? Under Model A the recognised costs are 110,647 RSD per quarter, a flat figure set by ZPDG čl. 12b st. 1. Under Model B they are 66,733 RSD per quarter under čl. 12b st. 2, increased by 34 percent of the quarterly gross under čl. 85 st. 5 t. 2 podtačka (2) for contracted work, or čl. 56 st. 2 t. 2 for copyright income. Where both types of income arise in the same quarter, the normirani troškovi are recognised once on the combined total under čl. 12b st. 3. ### How often does a Serbian freelancer choose between Model A and Model B? The model is chosen per quarter, not once and for all. Each quarterly PP OPO-K return stands on its own, so the same person can use Model A in one quarter and Model B in the next. The Poreska uprava publishes a calculator on frilenseri.purs.gov.rs that computes both models for a given quarter. ### Which form does a Serbian freelancer file for quarterly self-assessment? The quarterly form is PP OPO-K. PP OPO is a different form, used for income where the payer is not obliged to withhold tax, and it is filed within 30 days of receiving the income rather than on a quarterly cycle. The two are routinely confused, and their deadlines are not the same. ### When is the quarterly freelancer tax deadline in Serbia? The return is due within 30 days of the end of the quarter under ZPDG čl. 95 st. 7, and the tax is payable by the same deadline. That gives windows of 1 to 30 April for the first quarter, 1 to 30 July for the second and 1 to 30 October for the third, with the fourth quarter following the same 30-day rule. A paušalac is on a different cycle entirely, paying monthly within 15 days of the end of each month. ### Does a Serbian freelancer pay eko taksa and APR registration fees? No. The eko taksa obveznik list names legal entities, entrepreneurs and branches of foreign legal entities, and a person who is not registered as a business is none of those. There is no APR registration either, and so no APR fee. A paušalac pays 2,500 RSD to register at APR and is an eko taksa obveznik, typically 5,000 RSD per year for a low-impact service activity. ### Can the same person be a paušalac and use the freelancer regime at the same time? This is not something that can be stated from a primary source. Neither the Zakon o porezu na dohodak građana nor the Poreska uprava's freelancer portal was found to address the combination directly, and no official mišljenje on the point was located. Anyone actually in that position should put the question to the Poreska uprava or to an accountant rather than rely on a general answer. ### How does the independence test apply to a paušalac compared with the freelancer regime? The independence test in ZPDG čl. 85 st. 1 t. 17 is written around the relationship between a preduzetnik and each individual nalogodavac, and income reclassified under it is expressly excluded from the 6,000,000 RSD paušal turnover count by čl. 40 st. 5. Both rules presuppose a registered entrepreneur. Whether an equivalent reclassification reaches income declared under the freelancer regime could not be confirmed from a primary source, so it should not be assumed either way. --- ## Sources - [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) — "Sl. glasnik RS", br. 24/2001, consolidated through br. 6/2026 (čl. 12b, 38, 40, 41, 43, 58, 85, 86, 95, 110) - [Zakon o doprinosima za obavezno socijalno osiguranje](https://www.paragraf.rs/propisi/zakon_o_doprinosima_za_obavezno_socijalno_osiguranje.html) — "Sl. glasnik RS", br. 84/2004, consolidated through br. 6/2026 (čl. 22, 28, 35b, 44, 50) - [Poreska uprava — Preduzetnici paušalci](https://www.purs.gov.rs/preduzetnici-pausalci.html) - [Poreska uprava — portal za frilensere](https://frilenseri.purs.gov.rs/) - [Poreska uprava — Dva modela samooporezivanja: koji odabrati](https://frilenseri.purs.gov.rs/korisne-informacije/dva-modela-samooporezivanja-koji-odabrati.html) — cited here as an example of a stale official page - [PIO Fond — Osnovice za uplatu doprinosa](https://www.pio.rs/sr/osnovice-za-uplatu-doprinosa) — najniža mesečna osnovica, "Sl. glasnik RS", br. 112/2025 - [APR — Naknade za registraciju preduzetnika](https://www.apr.gov.rs/registri/preduzetnici/naknade.2066.html) — Odluka o naknadama, "Sl. glasnik RS", br. 95/2025 # Serbia's Annual Income Tax: Does Godišnji Porez Reach a Paušalac? Source: https://preduzmi.com/articles/annual-income-tax Published: 2026-07-24, updated 2026-08-21 > Serbia's annual income tax counts a paušalac's assessed income, but the 2025 non-taxable threshold is 5,439,096 RSD. Rates, the 10,878,192 RSD tax-base bracket, PP GPDG and the 15 May 2026 deadline. *Last updated: August 2026. Reflects the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, with amendments, consolidated through br. 6/2026). The rules below are cited to ZPDG articles. The dinar amounts for income year 2025 and the form name are cross-checked against two independent professional sources rather than read directly off the gazette — they are marked as such where they appear.* **In short** - **Does the annual tax reach a paušalac?** Yes in principle, rarely in practice. The *paušalno utvrđen prihod* counts toward the annual tax (ZPDG čl. 87 st. 2 t. 2), but for a paušalac it sits far below the threshold, so most never file. - **Neoporezivi iznos for income year 2025: 5,439,096 RSD** — three times the average annual salary (ZPDG čl. 87 st. 1). - **Rates: 10%** on a taxable base up to **10,878,192 RSD** (six times the average annual salary), **15%** on the excess (ZPDG čl. 89). The boundary is measured on the *osnovica*, after the non-taxable amount and the *lični odbici* come off — not on gross income. - **The figure that is widely published wrong: 9,749,016 RSD is the 2024 threshold**, not the 2025 one. It still appears in 2026 articles and in AI search summaries. - **Form and deadline:** **PP GPDG**, filed electronically through ePorezi by *samooporezivanje*, due **15 May 2026** for income year 2025 (ZPDG čl. 92 st. 1). - **It arrives pre-filled.** The Poreska uprava prepares the return and posts it by **1 April** (ZPDG čl. 92). Open it and check it. ## Where a paušalac sits in the annual tax A paušalac is inside the *godišnji porez na dohodak građana* in principle and outside it in practice. Both halves are true, and most published answers give only one of them. The legal half: income from *samostalna delatnost* is one of the income types the annual tax aggregates, and for a paušalac that means the **paušalno utvrđen prihod** — the assessed income set out in your *rešenje* (ZPDG čl. 87 st. 2 t. 2, referring to čl. 33 st. 2 and čl. 41). There is no carve-out for lump-sum taxpayers. If someone tells you paušalci are legally outside the annual tax, that is wrong. The practical half: the annual tax only applies to income above the *neoporezivi iznos*, which for income year 2025 is **5,439,096 RSD**. A paušalac's assessed income is not his turnover, and turnover itself is capped at 6,000,000 RSD (ZPDG čl. 40 st. 2 t. 4). The assessed figure lands well below the threshold for the activity codes paušalci typically register under, so paušal income alone does not trigger a filing. The two halves matter together. A paušalac who also draws a *zarada* from employment, or receives *autorska prava*, aggregates those with his assessed paušal income. That combination — not paušal income by itself — is what occasionally puts someone over the line. --- ## The figures for income year 2025 Every amount below is anchored to the **average annual salary in Serbia for 2025: 1,813,032 RSD**. The law expresses the thresholds as multiples of that figure, and the Republički zavod za statistiku publishes the salary; the dinar amounts follow arithmetically. | Item | Rule | Amount for income year 2025 | |---|---|---| | Prosečna godišnja zarada | Published by RZS | **1,813,032 RSD** | | Neoporezivi iznos | 3× average annual salary (ZPDG čl. 87 st. 1) | **5,439,096 RSD** | | Top of the 10% band, on the taxable base | 6× average annual salary (ZPDG čl. 89) | **10,878,192 RSD** | | Lični odbitak — taxpayer | 40% of average annual salary (ZPDG čl. 88) | **725,213 RSD** | | Lični odbitak — per dependent | 15% of average annual salary (ZPDG čl. 88) | **271,955 RSD** | | Additional reduction, under 40 | 3× average annual salary (ZPDG čl. 87 st. 4–5) | **5,439,096 RSD** | The **rules** in the middle column are verified against ZPDG. The **dinar amounts** in the right-hand column are cross-checked against two independent professional sources (KPMG Serbia and pktatic.rs) rather than read off the Službeni glasnik text. The rate structure itself is short, but it applies to the **taxable base**, not to gross income (ZPDG čl. 89): | Taxable base (*osnovica*) | Rate | |---|---| | Up to 10,878,192 RSD | **10%** | | Above 10,878,192 RSD | **10% on the first 10,878,192 RSD, then 15% on the excess** | The order of operations is where most published summaries go wrong: 1. **Dohodak** — the annual sum of the income types listed in ZPDG čl. 87 st. 2, each reduced by the tax and contributions already paid on it (čl. 87 st. 3). 2. **Dohodak za oporezivanje** — dohodak minus the *neoporezivi iznos* of 5,439,096 RSD (čl. 87 st. 8). 3. **Osnovica** — dohodak za oporezivanje minus the *lični odbici* (čl. 88). 4. **Tax** — 10% on the osnovica up to 10,878,192 RSD, 15% on anything above that (čl. 89). Read in that order, the 15% rate is further away than a flat reading of the table suggests: a base of 10,878,192 RSD already sits on top of the 5,439,096 RSD removed at step 2, plus whatever the *lični odbici* removed at step 3. --- ## The 15% threshold that is widely published wrong **The 15% bracket for income year 2025 starts at a taxable base of 10,878,192 RSD.** That is six times the 2025 average annual salary of 1,813,032 RSD, and ZPDG čl. 89 applies it to the *osnovica* — what is left after the *neoporezivi iznos* and the *lični odbici* — rather than to gross income. The number circulating instead is **9,749,016 RSD**. That figure is not invented — it is the correct threshold for **income year 2024**, filed in 2025, and it measures the same thing: six times that year's average annual salary, applied to the taxable base. It has simply been carried forward. It appears in articles published in 2026, in tax summaries, and in answers generated by AI search tools, which reproduce whatever the indexed pages say. The same drift affects the *neoporezivi iznos*: the 2025 figure is 5,439,096 RSD, and any 2024 number quoted alongside a 2025 filing deadline is a year out of date. **Check the year, not just the number** The annual-tax thresholds are recomputed every year from a statistic published the following February. A threshold quoted without an income year attached is unusable. Before relying on any figure, confirm it is stamped **"for income year 2025, filed in 2026"** — and not carried over from the previous cycle. --- ## What counts for a paušalac: assessed income, not turnover **The figure that enters the annual tax for a paušalac is the paušalno utvrđen prihod from the rešenje, not the money that arrived in the bank account.** This distinction does most of the work in answering whether a paušalac ever reaches the threshold. Your turnover is what you record in the KPO knjiga and what the 6,000,000 RSD limit is measured against; the [guide to the revenue limits](/articles/revenue-limits) explains how that limit is counted. Your assessed income is a separate figure, derived by formula from the average salary, employment and population data for your location and your activity coefficient, then adjusted by the coefficients in the Uredba. It is set once a year by the Poreska uprava in your *rešenje*, and it does not move when your invoicing moves. For how that number is actually derived, see the [guide to the paušal tax base](/articles/pausal-tax-base). The 10% *porez na prihode od samostalne delatnosti* you pay monthly (ZPDG čl. 38) is applied to that same assessed figure. It is a different tax from the annual one, on a different schedule, and paying it does not discharge or replace the annual tax. The monthly mechanics are covered in the [guide to monthly tax payments](/articles/tax-payments). So the honest answer to "how much would a paušalac need to earn to owe the annual tax" is: the question is about the assessed figure in the *rešenje*, not about invoices. For the activity codes most paušalci register under, that figure is an order of magnitude below 5,439,096 RSD, and other income sources are what change the picture. --- ## Lični odbici **The lični odbici are subtracted from the *dohodak za oporezivanje* to give the *osnovica* the rate is applied to (ZPDG čl. 88).** They reduce the base, not the tax, and they only come into play for income that has already cleared the *neoporezivi iznos* — below that threshold there is no annual tax for them to reduce. Two amounts exist for income year 2025: - **Taxpayer: 725,213 RSD** — 40% of the average annual salary. - **Each dependent family member: 271,955 RSD** — 15% of the average annual salary, per dependent. Two limits apply. The total of all *lični odbici* **cannot exceed 50% of the dohodak za oporezivanje**. And where more than one family member is liable for the annual tax, **only one of them may claim a given dependent** — the same dependent cannot be counted twice across two returns. --- ## The additional reduction for taxpayers under 40 **A taxpayer who was under 40 on the last day of the tax year gets a further reduction of three average annual salaries — 5,439,096 RSD for income year 2025 (ZPDG čl. 87 st. 4–5).** This reduction is not general. It reaches only the income types in ZPDG čl. 87 st. 2 t. 1–3 and t. 6b — *zarade*, income from *samostalna delatnost*, *autorska prava* and seafarers' income — and čl. 87 st. 5 caps it at the total of those incomes, so it can never produce a negative figure. It sits on top of the *neoporezivi iznos* rather than replacing it, which means the point at which the annual tax starts to reach those income types for an under-40 taxpayer is a further 5,439,096 RSD higher. The age test is a single date: your age on **31 December of the tax year**, not on the filing date. Someone who turned 40 in November 2025 does not qualify for income year 2025. --- ## The return arrives pre-filled by 1 April **The Poreska uprava prepares the annual return for you and posts it by 1 April (ZPDG čl. 92).** This is the part of the procedure most people do not know about, and it changes what you should actually do in April. The tax authority holds the data it needs — reported *zarade*, your paušal *rešenje*, and other reported income — so it assembles a draft return and places it in your ePorezi inbox. You are not waiting for a *rešenje* to tell you what you owe, the way you do with monthly obligations or with [eko taksa](/articles/eko-taksa). The practical advice follows from that: **open it and check it.** A pre-filled return is a statement of what the authority believes your income was. If it is empty or shows income below the threshold, you have your answer for the year and nothing further is required. If it shows income you do not recognise, or omits income you know about, that is something to resolve before 15 May, not after. There is also a consequence to ignoring it. If a taxpayer who owes the annual tax does not file by the deadline, ZPDG čl. 92 st. 4 has the Poreska uprava file the return for him. Silence is not an exit. Do not treat "I heard nothing" as confirmation that nothing is owed. Confirmation is what you find when you log in and look. --- ## Filing: PP GPDG, electronically, by samooporezivanje **The form is PP GPDG, it is filed electronically through ePorezi, and the assessment is by *samooporezivanje* — self-assessment.** There is no paper route and no waiting for the authority to issue a decision with an amount on it. You confirm or correct the return, submit it, and the liability follows from what you submitted. The deadline for income year 2025 is **15 May 2026** — ZPDG čl. 92 st. 1 sets it as 15 May of the year following the income year. Annual deadlines like this one are listed alongside the rest of the paušal year in the [paušal calendar checklist](/articles/calendar-checklist). **PPDG-2R is not the current form** Published guides — including some updated recently — still name **PPDG-2R** as the annual income tax return. Since the move to *samooporezivanje*, the annual return is **PP GPDG**, submitted electronically. If a source you are reading names PPDG-2R for the annual tax, treat the rest of its procedural detail as dated too. --- ## The threshold for income year 2026 does not exist yet **There is no published 2026 threshold, and anyone quoting one is projecting.** The thresholds are multiples of the average annual salary for the tax year, and the 2026 average annual salary will be published by the Republički zavod za statistiku in **February 2027**. That is the honest state of the record as of August 2026. When the statistic appears, the *neoporezivi iznos*, the 6× threshold, and both *lični odbici* recompute from it, and the 2025 amounts on this page become the previous cycle's figures — exactly the way 9,749,016 RSD became a stale number. **Indexed amounts can move mid-year** ZPDG carries a periodic republication of *usklađeni dinarski iznosi* — indexed dinar amounts — and those take effect from the first day of the month following publication, so a figure can change in the middle of a calendar year rather than only on 1 January. Before acting on any dinar amount in Serbian tax law, including the ones on this page, check whether a newer indexed set has been published. --- ## Key takeaways 1. The *paušalno utvrđen prihod* does count toward the annual income tax (ZPDG čl. 87 st. 2 t. 2), so a paušalac is not legally outside the regime — but the assessed figure sits far below the threshold, so most paušalci never file. 2. For income year 2025 the *neoporezivi iznos* is **5,439,096 RSD**, three times the 2025 average annual salary of 1,813,032 RSD (ZPDG čl. 87 st. 1). 3. The **15% band starts at a taxable base of 10,878,192 RSD** for 2025; up to that the rate is 10%, and the base is what remains after the *neoporezivi iznos* and the *lični odbici* come off (ZPDG čl. 87 st. 8, čl. 88, čl. 89). 4. **9,749,016 RSD is the 2024 threshold**, and it is still being republished as if it applied to 2025 income — including in AI-generated summaries. 5. The *lični odbici* for 2025 are 725,213 RSD for the taxpayer and 271,955 RSD per dependent, capped in total at 50% of the *dohodak za oporezivanje*, with each dependent claimable by only one family member (ZPDG čl. 88). 6. A taxpayer under 40 on 31 December of the tax year gets an additional reduction of 5,439,096 RSD for 2025, reaching only *zarade*, *samostalna delatnost*, *autorska prava* and seafarers' income, and capped at the total of those incomes (ZPDG čl. 87 st. 4–5). 7. The Poreska uprava posts a pre-filled return by **1 April** (ZPDG čl. 92); the form is **PP GPDG**, filed electronically by *samooporezivanje*, due **15 May 2026** for income year 2025. Preduzmi tracks paušal obligations and deadlines. It does not calculate anyone's annual income tax liability, and where several income types aggregate in one year, that is a conversation for an accountant rather than for software. --- ## Frequently asked questions ### Does a Serbian paušalac have to pay the godišnji porez na dohodak građana? In principle yes, in practice almost never. The paušalno utvrđen prihod assessed in a paušalac's rešenje is one of the income types that counts toward the annual income tax under ZPDG član 87 stav 2 tačka 2. But the annual tax only applies above the non-taxable threshold, which is 5,439,096 RSD for income year 2025, and a paušalac's assessed income sits far below that. Most paušalci therefore never file the annual return on the basis of their paušal income alone. ### What is the non-taxable threshold for Serbia's annual income tax for income year 2025? The neoporezivi iznos for income year 2025 is 5,439,096 RSD. The rule in ZPDG član 87 stav 1 sets it at three times the average annual salary in Serbia, and the 2025 average annual salary is 1,813,032 RSD. Income at or below that threshold is not subject to the annual income tax at all. ### When does the 15 percent rate start for Serbia's annual income tax on 2025 income? The 15 percent rate applies where the taxable base exceeds 10,878,192 RSD for income year 2025; up to that amount the rate is 10 percent. ZPDG član 89 expresses the boundary as six times the average annual salary, which for 2025 is six times 1,813,032 RSD, and it applies that boundary to the osnovica rather than to gross income. The osnovica is what remains after the non-taxable amount of 5,439,096 RSD and the lični odbici have been deducted, so in income terms the 15 percent rate starts considerably higher than 10,878,192 RSD. ### Is 9,749,016 RSD still the correct 15 percent threshold for Serbia's annual income tax? No. 9,749,016 RSD is the threshold for income year 2024, filed in 2025. For income year 2025 the correct figure is 10,878,192 RSD. Both are six times the average annual salary of their year and both are measured on the taxable base, not on gross income. The 2024 number is still being republished in articles dated 2026 and reproduced in AI search summaries, so check the income year attached to any threshold before relying on it. ### What is the deadline for filing Serbia's annual income tax return for 2025? The deadline is 15 May 2026 for income year 2025, set by ZPDG član 92 stav 1 as 15 May of the year following the income year. The return is filed electronically through the ePorezi portal by samooporezivanje, meaning the taxpayer self-assesses rather than waiting for the tax authority to issue a decision with an amount. The Poreska uprava posts a pre-filled version of the return by 1 April, and if an obligated taxpayer still does not file, član 92 stav 4 has the tax authority file it for him. ### Which form does a Serbian taxpayer use for the annual income tax, PP GPDG or PPDG-2R? The current form is PP GPDG, filed electronically through ePorezi. PPDG-2R is not the current annual income tax form since the move to samooporezivanje, although several published guides still name it. If a source names PPDG-2R for the annual tax, its other procedural details are likely to be out of date as well. ### Does the Poreska uprava pre-fill the annual income tax return in Serbia? Yes. Under ZPDG član 92 the Poreska uprava prepares the annual return using the income data it already holds and posts it to the taxpayer by 1 April. The taxpayer then checks it, corrects it if the data is wrong, and submits it by samooporezivanje. Because it arrives pre-filled, the sensible step in April is to log in to ePorezi and read it rather than assume nothing is owed. ### How does the under 40 reduction work in Serbia's annual income tax? A taxpayer who was under 40 on the last day of the tax year receives an additional reduction of three average annual salaries, which is 5,439,096 RSD for income year 2025, under ZPDG član 87 stavovi 4 and 5. It reaches only zarade, income from samostalna delatnost, autorska prava and seafarers' income, and stav 5 caps it at the total of those incomes so it cannot produce a negative figure. The age test is your age on 31 December of the tax year, not on the filing date. ### Does a paušalac's turnover or assessed income count toward Serbia's annual income tax? The assessed income counts, not the turnover. What enters the annual tax is the paušalno utvrđen prihod set in the rešenje under ZPDG članovi 33 and 41, which is derived by formula rather than from invoices. Turnover is the figure measured against the 6,000,000 RSD paušal limit and recorded in the KPO knjiga, and it is a separate number entirely. ### What is the non-taxable threshold for Serbia's annual income tax for income year 2026? It does not exist yet. The thresholds are multiples of the average annual salary for the tax year, and the 2026 average annual salary will be published by the Republički zavod za statistiku in February 2027. Any figure quoted for income year 2026 before that publication is a projection, not a published threshold. --- ## Sources - [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, with amendments consolidated through br. 6/2026) — čl. 33, čl. 38, čl. 40, čl. 41, čl. 87, čl. 88, čl. 89, čl. 92. - [Zakon o porezu na dohodak građana — consolidated text on paragraf.rs](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) — the text the article's citations were read against. - [Poreska uprava Republike Srbije — preduzetnici paušalci](https://www.purs.gov.rs/preduzetnici-pausalci.html) — paušal status, assessed income and the *rešenje*. - [ePorezi portal](https://eporezi.purs.gov.rs/) — where the pre-filled PP GPDG return is posted and filed. - [Republički zavod za statistiku](https://www.stat.gov.rs/) — publisher of the average annual salary the thresholds are derived from. The dinar amounts for income year 2025 in this article are cross-checked against two independent professional tax sources (KPMG Serbia and pktatic.rs). The rules they implement are cited to ZPDG above. # Registering as a Paušalac in Serbia: The First 30 Days Source: https://preduzmi.com/articles/registering-as-pausalac Published: 2026-07-20, updated 2026-08-21 > A new paušalac elects paušal taxation inside the APR registration application itself, not through a separate 15-day filing. Eligibility, 2026 APR fees, and an ordered first-30-days checklist. *Last updated: August 2026. This guide reflects the [Zakon o porezu na dohodak građana](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2001/80/7/reg) ("Sl. glasnik RS", br. 24/2001, consolidated through 6/2026), the* Uredba o bližim uslovima, kriterijumima i elementima za paušalno oporezivanje *("Sl. glasnik RS", br. 94/2019, with amendments through 115/2025), and the APR* Odluka o naknadama *("Sl. glasnik RS", br. 95/2025).* **In short** - **A new entrepreneur elects paušal taxation inside the APR registration application itself.** ZPDG čl. 42 st. 2: the request is filed *"isključivo u momentu registracije"* with the business registers agency, which forwards it to the Poreska uprava. - **There is no separate 15-day tax filing for a new paušalac.** The 15-day rule people cite is ZPDG čl. 94 st. 1, and it applies to obligors *"osim preduzetnika paušalca"* — that is, to knjigaši. - **An existing entrepreneur switching to paušal files by 31 October** of the current year, for the following year, electronically via ePorezi (ZPDG čl. 42 st. 1). - **APR registration costs 2,500 RSD** from 1 January 2026 (Odluka o naknadama, Sl. glasnik RS 95/2025, čl. 8 i 9). The 850, 750 and 1,600 RSD figures still circulating are pre-2026. - **The coefficient for the year of registration is 0.5** (Uredba čl. 5 t. 2), rising to 1.0 from the fourth year. - **No eko taksa is owed for the calendar year in which the business was registered** (Zakon o naknadama čl. 137 st. 2) — but Obrazac 1 is still filed. --- ## The eligibility gate Paušal taxation is available to entrepreneurs whose registered activity is not on the statutory exclusion list, whose prior-year turnover — or, for a business just starting, whose *planirani promet* — does not exceed **6,000,000 RSD**, and who are not registered VAT payers (ZPDG čl. 40 st. 2). ZPDG čl. 40 st. 2–3 excludes an entrepreneur who: - performs activities in the field of **reklamiranje i istraživanje tržišta** (advertising and market research); - performs activities in **trgovina na veliko i trgovina na malo** (wholesale and retail trade), **hoteli i restorani** (hotels and restaurants), **finansijsko posredovanje** (financial intermediation), or **poslovi u vezi sa nekretninama** (real-estate business); - carries on an activity into which **other persons have invested capital**; - had **total turnover above 6,000,000 RSD** in the year preceding the year of assessment, or — when the activity is only beginning — whose **planned turnover exceeds 6,000,000 RSD** (čl. 40 st. 2 t. 4); - is **registered as a VAT payer** (čl. 40 st. 2 t. 5). There is one carve-out. ZPDG čl. 40 st. 3 allows an entrepreneur carrying on **trade or hospitality** (*trgovinska ili ugostiteljska delatnost*) from a **kiosk, trailer or similar prefabricated or movable facility** to be granted paušal status on request, despite the exclusion in st. 2 t. 2. A first-year registrant is not outside the turnover test. Where there is no preceding year, ZPDG čl. 40 st. 2 t. 4 applies the same 6,000,000 RSD line to the **planirani promet** — the turnover planned when the activity begins. The exclusion that decides most cases is still the **activity list**, and it turns on the *pretežna delatnost* (šifra delatnosti) you choose in the APR application. Choose it before you file, not after. **The exclusions follow the activity, not the invoice** An IT consultant who registers under a trade code is excluded from paušal even if every invoice is for consulting. The register entry is what the Poreska uprava reads. If you are weighing paušal against full bookkeeping, [paušalac vs knjigaš](/articles/pausalac-vs-knjigash) sets out what changes on the other side of that line. --- ## How the election is actually made **A new entrepreneur elects paušal taxation through the APR registration application, at the moment of registration — not through a later filing with the Poreska uprava.** ZPDG čl. 42 st. 2 is explicit: the request for paušal taxation is submitted *"isključivo u momentu registracije nadležnoj organizaciji koja vodi registar privrednih subjekata, koja će taj zahtev proslediti Poreskoj upravi"*. And ZPDG čl. 94 st. 2 provides that an obligor who starts a self-employed activity during the year elects paušal taxation *"u prijavi za registraciju"*, **in which case he is deemed to have filed the tax return** — *"u kom slučaju se smatra da je podneo poresku prijavu za paušalno oporezivanje"*. You tick the box in the APR form; the tax-return obligation is discharged by that act. APR describes the same thing from its own side. Registration runs through the *jednošalterski sistem*, and APR states that with the founding decision the entrepreneur simultaneously receives the **matični broj** (Republički zavod za statistiku), the **PIB** (Poreska uprava – Centrala), the **prijava na paušalno oporezivanje** (or, instead, the election of *lična zarada* or VAT), the CROSO registration confirmation (**Obrazac M-A**) and a health-insurance number from RFZO. The widely repeated advice — "register, then file within 15 days to request paušal" — comes from **ZPDG čl. 94 st. 1**, which prescribes a start-of-business return for obligors *"osim preduzetnika paušalca"*. The rule exists. It is simply not a paušalac rule. It is the knjigaš rule. | Who you are | What you file | Deadline | Citation | |---|---|---|---| | **New entrepreneur registering with APR** | The paušal request inside the APR registration application | At the moment of registration; no separate filing | ZPDG čl. 42 st. 2; čl. 94 st. 2 | | **Existing entrepreneur switching to paušal** | Electronic request via ePorezi | **31 October** of the current year, for the following year | ZPDG čl. 42 st. 1 | | **Existing entrepreneur just removed from the VAT register** | Electronic request via ePorezi | Within **15 days** of the PU act confirming removal, and no later than **31 December**, for the following year | ZPDG čl. 42 st. 1 | | **Obligor not registered with APR** | Electronic request via the PU portal | Within **5 days** of registration with the PU / PIB assignment, and no later than **31 December** | ZPDG čl. 42 st. 3 | The 31 October deadline is annual and hard. The most recent instance: the request for paušal status for **2026** had to be filed electronically via ePorezi by **Friday, 31 October 2025**. Miss it and the earliest available start is the year after next. **The 15-day deadline you have read about is not yours** If you are registering a new preduzetnik with APR and you selected paušal in the application, there is nothing further to file with the Poreska uprava to obtain the status. If a source tells you otherwise, ask it to name the article. ZPDG čl. 94 st. 1 excludes paušalci by its own wording. --- ## What APR registration costs in 2026 **Registering a preduzetnik with APR costs 2,500 RSD** from 1 January 2026, under the Odluka o naknadama ("Sl. glasnik RS", br. 95/2025), čl. 8 i 9. | APR service | Fee from 1 Jan 2026 (RSD) | |---|---| | **Osnivanje preduzetnika** (registration) | **2,500** | | Promena podataka (change of registered data) | **1,400** | | Each additional change in the same application | +700 | | Brisanje (deregistration) | **1,400** | | Izvod iz registra | 1,500 | | Potvrda | 1,000 | | Rezervacija naziva | 1,400 | The **850, 750 and 1,600 RSD** figures still circulating in guides and forum threads are the **pre-2026 schedule and are wrong**. They were superseded on 1 January 2026. APR decides on a registration application within **5 radnih dana** under the Zakon o postupku registracije u Agenciji za privredne registre. Read that number correctly: it is **APR's** deadline for deciding, not a deadline imposed on you. --- ## Why the month you register in matters **The coefficient applied in the calendar year of registration is 0.5** — the lowest step on the ladder (Uredba čl. 5 t. 2). It then rises with the age of the business. | Time registered as an entrepreneur | Coefficient | |---|---| | **The calendar year of registration** | **0.5** | | Up to 12 months | 0.8 | | Over 12 to 24 months | 0.85 | | Over 24 to 36 months | 0.9 | | Over 36 months | 1.0 | This coefficient is one multiplier in the formula that produces your assessed paušal income; the full computation is set out in [how the paušal base is computed](/articles/pausal-tax-base). The mechanical consequence is about **duration, not amount**. The 0.5 step attaches to the *calendar year of registration*, so registering in January gives you twelve months on that step, and registering in October gives you three. The ladder then advances on the same schedule either way. One exception in the same provision: an entrepreneur who **was already registered as a preduzetnik less than 18 months earlier** is placed on the coefficient 1, not on the entry step. Closing and reopening does not reset the ladder. Uredba čl. 5 st. 2–3 also sets a floor: the cumulative product of all applicable coefficients cannot fall below 0.5. --- ## The first 30 days, in order The obligations start on the day the registration takes effect, not on the day the Poreska uprava sends you a rešenje. Work through these in sequence. **1. Collect the APR rešenje and your PIB.** APR issues a registration decision within 5 radnih dana. It carries your matični broj and your PIB, and every step below depends on it. APR also notes that the data exchange with CROSO and the Poreska uprava at founding is a **one-off** transfer: any later correction has to be taken directly to CROSO or to PU Centrala, not to APR. **2. Open a business bank account.** In practice every Serbian bank operates a *tekući račun preduzetnika* separate from a personal account, and will ask for the APR rešenje and identification to open one. If any of your clients pay in foreign currency, ask the bank to open the devizni podračun at the same time — see [foreign-currency inflows](/articles/foreign-currency-inflows). **3. Obtain a qualified electronic certificate and register on ePorezi.** A *kvalifikovani elektronski sertifikat* is what gets you into the ePorezi portal — you need it to read your tax mailbox and to file anything electronically. Certificates are issued by the bodies on the register of certification bodies; check the current list before you buy one, because the issuers and the media they use change. **4. Start the KPO knjiga with your first invoice.** ZPDG čl. 43 st. 4 requires paušalci to keep *"samo poslovnu knjigu o ostvarenom prometu"* — one book, recording turnover only. It starts at entry number 1 with your first invoice, not at the end of the quarter. [The KPO guide](/articles/kpo-book) covers what goes in and what does not. **5. File Obrazac 1 with your LPA within 15 days.** The eko taksa filing goes to the **lokalna poreska administracija**, not to the Poreska uprava, and is due within 15 days of registering the start of activity (Zakon o naknadama čl. 138 st. 3). **6. Note your first payment date.** The monthly paušal obligation is due **within 15 days of the end of each month** (ZPDG čl. 110 t. 1). The same deadline governs the contributions (ZDOSO čl. 60 st. 1). **No eko taksa in your registration year — but file anyway** Zakon o naknadama čl. 137 st. 2 provides that **no fee is owed for the calendar year in which the entity was registered**. This is almost never published, and many new paušalci pay a year they did not owe. The **filing obligation is separate and remains**: submit Obrazac 1, receive a rešenje showing nothing due, and you have a record in the LPA's system. [The eko taksa guide](/articles/eko-taksa) covers the form, the deadlines and the amounts from year two. --- ## The rešenje, and the clock that starts when it arrives Your monthly obligation is not a number you calculate. The Poreska uprava assesses it by rešenje, and delivers it electronically into your ePorezi tax mailbox. **A tax act is deemed served on the day it is posted to the Poreska uprava portal** — ZPPPA čl. 36: *"smatra dostavljenim danom postavljanja na portal Poreske uprave"*. And under čl. 36 an act may be delivered electronically to anyone who files tax returns electronically *"u kom slučaju nije neophodna dodatna saglasnost"* — no separate consent, and no guarantee that a notification reaches you by another channel. The **appeal deadline is 15 days from receipt** of the poreski upravni akt (ZPPPA čl. 142), and for an act posted to the portal receipt is that posting date — whether or not you have logged in. Filing an appeal does not buy you time to pay: **ZPPPA čl. 147 st. 1** states that *"žalba ne odlaže izvršenje poreskog upravnog akta"*, with a narrow exception in st. 2 where the second-instance body defers execution on documented substantial economic damage. Check the mailbox. That is the reason step 3 above is not optional. Once you have the rešenje, the monthly amount is 10% income tax (ZPDG čl. 38) plus 35.05% in contributions (ZDOSO čl. 44 st. 1) on the assessed base. The account numbers, payment codes and the poziv na broj all come from the rešenje itself — **verify them against your own document before the first transfer**. A payment posted to the wrong reference is treated as unpaid. [Monthly tax payments](/articles/tax-payments) covers the mechanics. --- ## After the first month **Paušal status runs indefinitely, with no annual re-application.** ZPDG čl. 42 st. 4: the taxpayer uses this method of taxation *"dok se ne utvrdi da su prestali razlozi za paušalno oporezivanje"* — until it is established that the grounds for paušal taxation have ceased. There is no renewal form and no annual confirmation. Two filings can arise later. If **the scope of your business or your turnover changed significantly** in the preceding year, or other conditions relevant to the assessment changed, a tax return is due **by 31 January** of the year for which the tax is assessed (ZPDG čl. 93 st. 2). If you **change your pretežna delatnost**, a return is due by **31 January of the year following the change** (Uredba čl. 3 st. 3–5). Filed on time, the new coefficient applies from the next tax period. Filed late, the Poreska uprava may apply it retroactively from the first day of the period in which the change occurred. Everything else — the monthly payment, the KPO entries, the annual eko taksa from year two — is recurring. [The paušalac compliance calendar](/articles/calendar-checklist) lays out the year. Preduzmi tracks these obligations and their dates for you. It does not give tax advice, and it is not a substitute for an accountant where your situation is genuinely complex. --- ## Key takeaways 1. A new entrepreneur elects paušal taxation **inside the APR registration application**, and that election counts as the tax return (ZPDG čl. 42 st. 2; čl. 94 st. 2). 2. The **15-day filing rule is ZPDG čl. 94 st. 1** and applies to obligors *"osim preduzetnika paušalca"* — it is a knjigaš obligation, routinely mis-attributed to paušalci. 3. An **existing** entrepreneur switches by filing electronically via ePorezi **by 31 October** for the following year, or within 15 days of removal from the VAT register and no later than 31 December (ZPDG čl. 42 st. 1). 4. **APR registration costs 2,500 RSD** from 1 January 2026, and APR decides within 5 radnih dana (Odluka o naknadama, Sl. glasnik RS 95/2025, čl. 8 i 9). 5. The **coefficient in the year of registration is 0.5**, rising through 0.8, 0.85 and 0.9 to 1.0 from the fourth year (Uredba čl. 5 t. 2); a re-registration within 18 months goes straight to 1. 6. **No eko taksa is owed for the registration year** (Zakon o naknadama čl. 137 st. 2), but **Obrazac 1 must still be filed with the LPA within 15 days** (čl. 138 st. 3). 7. The KPO starts with your first invoice (ZPDG čl. 43 st. 4), and the first monthly payment is due **within 15 days of the end of that month** (ZPDG čl. 110 t. 1). --- ## Frequently asked questions ### How does a new entrepreneur in Serbia elect paušal taxation? Through the APR registration application itself. ZPDG čl. 42 st. 2 states that the request for paušal taxation is filed exclusively at the moment of registration with the agency that maintains the register of business entities, which then forwards it to the Poreska uprava. Under ZPDG čl. 94 st. 2, opting for paušal in that application counts as having filed the tax return, so no separate submission to the Poreska uprava is required. ### Is there a 15-day deadline to apply for paušal status in Serbia? No, not for a new paušalac. The 15-day rule is ZPDG čl. 94 st. 1, and by its own wording it applies to obligors other than lump-sum entrepreneurs, meaning entrepreneurs who keep business books. A new paušalac who selected paušal taxation in the APR registration application has nothing further to file to obtain the status. This deadline is one of the most frequently mis-attributed rules in Serbian small-business guidance. ### When must an existing Serbian entrepreneur apply to switch to paušal taxation? By 31 October of the current year, for the following year, filed electronically through the ePorezi portal under ZPDG čl. 42 st. 1. There is one alternative route: an entrepreneur removed from the VAT register may file within 15 days of the tax authority act confirming the removal, and in any case no later than 31 December. The deadline for the 2026 paušal request was 31 October 2025. ### How much does it cost to register as a paušalac in Serbia in 2026? Registering a preduzetnik with APR costs 2,500 RSD from 1 January 2026, under the Odluka o naknadama published in Sl. glasnik RS 95/2025. A change of registered data costs 1,400 RSD, with 700 RSD for each additional change in the same application, and deregistration costs 1,400 RSD. The older figures of 850, 750 and 1,600 RSD still circulating online are from the pre-2026 schedule and no longer apply. ### Which activities cannot be taxed as a paušalac in Serbia? ZPDG čl. 40 st. 2 excludes advertising and market research, wholesale and retail trade, hotels and restaurants, financial intermediation, and real-estate business. It also excludes any activity into which other persons have invested capital, any entrepreneur whose turnover in the preceding year exceeded 6,000,000 dinars or whose planned turnover at the start of the activity exceeds that figure, and any registered VAT payer. ZPDG čl. 40 st. 3 provides a narrow exception, on request, for trade or hospitality carried out from a kiosk, trailer or similar movable facility. ### Does a Serbian paušalac have to reapply for paušal status every year? No. Under ZPDG čl. 42 st. 4, paušal status runs indefinitely and lasts until it is established that the grounds for paušal taxation have ceased. There is no annual renewal form and no yearly confirmation to file. Separate returns arise only if turnover or the scope of the business changed significantly in the preceding year, or if the registered primary activity changed. ### Does the month of registration affect a Serbian paušalac's tax base? It affects how long the entry-level coefficient applies, not the coefficient itself. Uredba čl. 5 t. 2 sets a coefficient of 0.5 for the calendar year in which the business is registered, then 0.8, 0.85, 0.9 and finally 1.0 from the fourth year. Because the 0.5 step is tied to the calendar year of registration, registering in January gives twelve months on that step and registering in October gives three. ### Does a new Serbian paušalac pay eko taksa in the first year? No fee is owed for the calendar year in which the business was registered, under Zakon o naknadama za korišćenje javnih dobara čl. 137 st. 2. The filing obligation is separate and remains in force: Obrazac 1 must be submitted to the local tax administration within 15 days of registering the start of activity, under čl. 138 st. 3. The local administration then issues a decision confirming that nothing is due for that year. ### When is a new Serbian paušalac's first monthly tax payment due? Within 15 days of the end of the month, under ZPDG čl. 110 t. 1, which sets the deadline as 15 days after the expiry of each month for lump-sum assessed income from self-employment. The same deadline governs the mandatory social contributions through ZDOSO čl. 60 st. 1. The amounts, account numbers and the poziv na broj all come from the rešenje issued by the Poreska uprava, and you should verify them against your own document before making a transfer. ### Does a Serbian paušalac need to keep a KPO knjiga from the first day? Yes. ZPDG čl. 43 st. 4 requires lump-sum entrepreneurs to keep only one business book, the book of realised turnover, and that obligation applies from the start of the activity. The first invoice you issue is entry number one. There is no grace period and no threshold below which the book can be skipped. --- ## Sources - [Zakon o porezu na dohodak građana](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2001/80/7/reg) ("Sl. glasnik RS", br. 24/2001, consolidated through 6/2026) — čl. 38, 40, 42, 43, 93, 94, 110. - *Uredba o bližim uslovima, kriterijumima i elementima za paušalno oporezivanje obveznika poreza na prihode od samostalne delatnosti* ("Sl. glasnik RS", br. 94/2019, with amendments through 115/2025) — čl. 3, čl. 5. - [Zakon o naknadama za korišćenje javnih dobara](https://www.mfin.gov.rs/sr/propisi-1/zakon-o-naknadama-za-koriscenje-javnih-dobara-1) ("Sl. glasnik RS", br. 95/2018, with amendments) — čl. 137, čl. 138. - [Agencija za privredne registre — naknade za registraciju preduzetnika](https://www.apr.gov.rs/registri/preduzetnici/naknade.2066.html), reflecting the *Odluka o naknadama* ("Sl. glasnik RS", br. 95/2025), čl. 8 i 9. - [Agencija za privredne registre — osnivanje preduzetnika](https://www.apr.gov.rs/registri/preduzetnici/uputstva/osnivanje.2058.html) — the *jednošalterski sistem*: matični broj, PIB, the paušal election, Obrazac M-A and the RFZO number issued together with the founding decision. - *Zakon o poreskom postupku i poreskoj administraciji* — čl. 36 (electronic service via the PU portal, no separate consent), čl. 142 (15-day appeal from receipt), čl. 147 (an appeal does not suspend execution). - *Zakon o doprinosima za obavezno socijalno osiguranje* — čl. 44, čl. 60. - [Poreska uprava Republike Srbije — preduzetnici paušalci](https://www.purs.gov.rs/preduzetnici-pausalci.html). # Does a Paušalac Need SEF? Serbia's E-Invoicing Rules in Four Questions Source: https://preduzmi.com/articles/sef-e-invoicing Published: 2026-07-07, updated 2026-08-21 > Whether a Serbian paušalac must use SEF depends on four questions: VAT status, public-sector clients, voluntary registration, and nothing else. Plus the repealed CRF duty and the real e-otpremnice dates. *Last updated: August 2026. This guide reflects the [Zakon o elektronskom fakturisanju](https://www.efaktura.gov.rs/tekst/9490/zakon-o-elektronskom-fakturisanju-04122025.php) ("Sl. glasnik RS", br. 44/2021, 129/2021, 138/2022, 92/2023, 94/2024 i 109/2025) and the [Zakon o elektronskim otpremnicama](https://www.paragraf.rs/propisi/zakon-o-elektronskim-otpremnicama.html) ("Sl. glasnik RS", br. 94/2024 i 109/2025).* **In short** - **The default answer is no.** A paušalac who is not in the VAT system and invoices only private domestic clients is **not obliged** to use SEF (ZEF čl. 3 st. 1, čl. 5 st. 1). - **VAT registration flips it to yes.** A *subjekt privatnog sektora* is defined as a VAT payer (ZEF čl. 2 st. 1 t. 3), and for one, SEF is mandatory (ZEF čl. 3, čl. 5). - **A public-sector client flips it to yes**, and you must register **before submitting the payment request** (ZEF čl. 2 st. 2). - **Voluntary registration is binding for the current plus the following calendar year** (ZEF čl. 5 st. 7–8). This is the trap. - **There is no separate CRF registration.** ZEF čl. 23 repealed the CRF-registration provisions as of **30 April 2022**; the register is now fed from the electronic invoice instead of from a filing of your own. - **E-otpremnice reach private-to-private trade on 1 October 2027**, not 1 January 2027 — while private-to-**public** sending has been due since 1 January 2026 (ZEO čl. 16). A services-only paušalac is outside the law at every stage. ## The decision in one table Four questions settle it, asked in this order. The first "yes" is your answer. | Your situation | SEF | Legal basis | |---|---|---| | Registered for VAT (PDV) | **Mandatory** | ZEF čl. 2 st. 1 t. 3; čl. 3; čl. 5 | | Invoicing a public-sector body | **Mandatory — register before you submit the payment request** | ZEF čl. 2 st. 2 | | Already registered as *dobrovoljni korisnik* | **Mandatory in the current and the following calendar year** | ZEF čl. 2 st. 1 t. 4; čl. 5 st. 7–8 | | None of the above | **Not required** | ZEF čl. 3 st. 1; čl. 5 st. 1 | Note what is missing from that list: your revenue, your *šifra delatnosti*, whether your clients are on SEF, and whether you invoice in EUR. None of them create the obligation. --- ## Question 1: VAT registration **A VAT-registered paušalac must use SEF.** ZEF čl. 2 st. 1 t. 3 defines a *subjekt privatnog sektora* as a VAT payer other than a public-sector entity, and čl. 3 and čl. 5 make the system compulsory for private-sector subjects. This is the single most common route into SEF for an entrepreneur who started outside it. VAT registration is triggered by turnover of more than **8,000,000 RSD over the previous 12 months** (ZPDV čl. 33 st. 1), after which you have **5 days** to file the *evidenciona prijava* (ZPDV čl. 38 st. 1). The 8-million limit and the 6-million paušal limit are different thresholds under different laws, and only the VAT one reaches SEF. Crossing 6,000,000 RSD costs you paušal status; it does not by itself put you on SEF. The two clocks are explained in the [guide to the 6-million and 8-million limits](/articles/revenue-limits). --- ## Question 2: public-sector clients **Invoicing a public-sector body makes SEF mandatory, and the timing is specific.** ZEF čl. 2 st. 2 requires registration *"pre podnošenja zahteva za isplatu subjektu javnog sektora"* — before you submit the payment request to the public-sector body, not after the invoice is issued and not when the money arrives. This catches paušalci who never expected to be on SEF: one training contract with a school, one design job for a municipality, one consulting engagement for a public agency. A single public-sector counterparty is enough. The obligation attaches to the transaction, so it is worth deciding before you sign, not after the work is delivered. --- ## Question 3: a voluntary registration you already made **A *dobrovoljni korisnik* is bound to use SEF in the current and the following calendar year** (ZEF čl. 5 st. 7–8). ZEF čl. 2 st. 1 t. 4 defines the category as a taxpayer on income from independent activity — a paušalac — **who has registered**. Registration is what creates the duty. Before it, the law does not reach you; after it, you are treated as a private-sector subject under ZEF čl. 2 st. 3. That means every invoice to a counterparty in the system goes through SEF, and you must **receive and store incoming electronic invoices** as well as issue them. **The voluntary-registration trap** People register on SEF because one client asked for it, or because it looked tidier than PDF invoices. The lock-in in ZEF čl. 5 st. 7–8 runs for the **current plus the following calendar year**, so a registration made in November 2026 realistically ends no earlier than 1 January 2028. Register when a client genuinely requires it or when you are about to enter the VAT system. Do not register to try it out. --- ## Question 4: none of the above **A non-VAT paušalac invoicing private domestic clients is not obliged to use SEF** (ZEF čl. 3 st. 1, čl. 5 st. 1). He is not a private-sector subject, not a public-sector entity, and not a tax representative of a foreign person — the three categories the obligation is built on. The practical consequence: you keep issuing ordinary invoices with the non-VAT notation, and you keep recording them in the [KPO knjiga](/articles/kpo-book). Nothing about SEF changes what the KPO must contain. Clients on SEF sometimes ask you to send through the system anyway. You can decline, and you can also accept — but accepting means registering, and registering means the lock-in above. It is a contractual question dressed as a technical one. --- ## The CRF correction: the separate registration duty was repealed **There is no separate CRF filing for a paušalac.** ZEF čl. 23 repealed the CRF-registration provisions of the *Zakon o rokovima izmirenja novčanih obaveza u komercijalnim transakcijama* — čl. 2 t. 9, čl. 4a st. 1–4, čl. 4b, čl. 4v, čl. 4g and the matching penalty provisions in čl. 12 — with effect from **30 April 2022**. Note the limits of that. The repeal is partial: the rest of that law, including the payment deadlines it sets for commercial transactions, is still in force. What disappeared is the duty to register an invoice in the *Centralni registar faktura* as a step of its own, and the creditor deadline attached to it. The register itself still exists and is now fed from the electronic invoice — ZEF's 138/2022 transitional provisions refer to "elektronske fakture koje se evidentiraju u centralni registar faktura". If a page tells you to register an invoice in the CRF as a separate action within a few working days of issuing it, it is describing the pre-2022 regime. For a paušalac invoicing a public-sector body, the sequence is now: register on SEF, issue the electronic invoice, submit the payment request. The CRF entry follows from the SEF record. --- ## Elektronsko evidentiranje: two obligations, and who they bind *Elektronsko evidentiranje obračuna PDV* is a separate duty inside SEF, and it is not the same thing as issuing e-invoices. The version of ZEF čl. 4 quoted below has applied to tax periods beginning after **31 December 2024** — in practice, from January 2025 (ZEF, 94/2024, samostalni čl. 14). | Obligation | Who it binds | Deadline | Basis | |---|---|---|---| | Elektronsko evidentiranje obračuna PDV | a *poreski dužnik* who is a VAT payer, plus persons outside the VAT system who are public-sector entities **or** *dobrovoljni korisnici* of SEF | the **12th** of the month following the tax period | ZEF čl. 4 st. 1 | | Elektronsko evidentiranje prethodnog poreza | **VAT payers only** | — | ZEF čl. 4a | | Neither | a non-VAT paušalac who has never registered on SEF | — | derived from ZEF čl. 4 st. 1 | For an unregistered non-VAT paušalac, the effect of both is **none**. There is no monthly filing, no 12th-of-the-month deadline, and nothing to reconcile. **Unresolved: the reverse-charge case for a dobrovoljni korisnik** If you are a non-VAT paušalac, you registered on SEF voluntarily, **and** you become a *poreski dužnik* through reverse charge on services bought abroad — the classic case is a foreign SaaS subscription — the wording of ZEF čl. 4 st. 1 appears to bring you into monthly *elektronsko evidentiranje obračuna PDV*. **We found no official mišljenje settling this.** The statutory text is verified; its application to this exact combination is not. This is the most consequential open point for this audience, because it would create an unexpected monthly filing obligation for someone who registered on SEF as a convenience. If this could be your situation, ask Poreska uprava or your accountant for a **written** opinion **before** you register voluntarily — not after, because the lock-in gives you no quick way out. Preduzmi tracks obligations; it does not replace an accountant on a question the ministry has not answered. --- ## Leaving SEF once you are in **There is no notice period, but there is a lock-in.** ZEF čl. 5 st. 8 binds a *dobrovoljni korisnik* for the current and the following calendar year. The earliest realistic exit is 1 January of the year after the one in which you registered. The exit is written into the *Pravilnik o elektronskom fakturisanju*. Čl. 34b names the expiry of the ZEF čl. 5 st. 8 period as one of the grounds for being struck from the *lista korisnika*. Čl. 34v says the request goes **electronically to the Centralni informacioni posrednik** — the unit inside the Ministry of Finance that runs SEF. Professional sources give its address as **cip@mfin.gov.rs**. Verify the current procedure and the current address on `efaktura.gov.rs` before you send anything — that is your step to confirm, not ours, and the pravilnik is amended every few months. A VAT-registered paušalac cannot leave at all while VAT registration stands. There the exit is the VAT deregistration, not a SEF request. --- ## E-otpremnice: the dates most pages get wrong **The private-to-private e-otpremnica obligation starts on 1 October 2027, not 1 January 2027.** The law is the *Zakon o elektronskim otpremnicama* ("Sl. glasnik RS", br. 94/2024 i 109/2025), and its čl. 16 sets a separate date for each direction of trade rather than one switch for everybody. | Obligation | From | Legal basis | |---|---|---| | Public sector receives; public sector sends to public sector | **1 January 2026** | ZEO čl. 16 st. 2 | | Private sector **sends** excise goods | **1 January 2026** | ZEO čl. 16 st. 3 | | Private sector **receives** excise goods | **1 January 2026** | ZEO čl. 16 st. 4 | | Private sector **sends to the public sector** | **1 January 2026** | ZEO čl. 16 st. 5 | | Public sector sends on any movement of goods | **1 January 2026** | ZEO čl. 16 st. 6 | | Private sector **receives** on any movement of goods | **1 October 2027** | ZEO čl. 16 st. 7 | | Private sector **sends to the private sector** | **1 October 2027** | ZEO čl. 16 st. 8 | Two dated side-notes come from the 109/2025 amendments, and neither is a phase of the rollout. Formal errors in sent otpremnice and prijemnice are disregarded in supervision **from 1 January to 30 June 2026**. The provisions on the **paper-form** e-otpremnica apply **from 1 April 2026**. That date is about the paper variant only. It is not, as some summaries have it, the day private-to-public sending began — that was 1 January 2026. **A services-only paušalac is outside the law at every stage.** ZEO čl. 2 t. 4 makes a person who is not a VAT payer a *subjekt privatnog sektora* only where excise goods are involved, and čl. 3 attaches the duty to send to a *movement of goods*. If you deliver software, consulting, design, photography or teaching, there is no goods movement to document, so no electronic waybill obligation attaches to you. The 1 January 2027 date circulating on several accounting blogs is simply wrong, and it has been repeated often enough that it now shows up in AI summaries. --- ## Penalties **For a preduzetnik that is a *subjekt privatnog sektora*, the fine band is 50,000 to 500,000 RSD** (ZEF čl. 18). It covers failures such as not issuing an electronic invoice where one is required and not complying with the rules of the system. The band applies only to someone inside the scope of the law. For a paušalac that means one of three statuses: VAT payer, supplier to the public sector, or *dobrovoljni korisnik*. Outside those, there is no SEF obligation to breach. --- ## What changes often, and what does not SEF mechanics move constantly. The platform has been on version **4.1.0** in production since **2 August 2026**, and the *Pravilnik o elektronskom fakturisanju* was last amended by "Sl. glasnik RS", br. **71/2026**, effective **1 August 2026**. Screens, XML schemas and API details from a year-old guide are usually stale. The scope rules have been stable since the 138/2022 amendments. The 109/2025 changes, which apply from tax periods beginning after **31 March 2026**, and the deferral of the *preliminarna poreska prijava* to tax periods beginning after **31 December 2026**, **do not change a paušalac's position** on any of the four questions above. The practical rule: trust an old article on *whether* you must be on SEF; verify anything it says about *how* the screens work. --- ## Key takeaways 1. **A non-VAT paušalac invoicing private domestic clients has no SEF obligation** — ZEF čl. 3 st. 1 and čl. 5 st. 1 build the duty on categories he does not fall into. 2. **VAT registration makes SEF mandatory**, because ZEF čl. 2 st. 1 t. 3 defines a private-sector subject as a VAT payer; crossing **8,000,000 RSD** over the previous 12 months (ZPDV čl. 33 st. 1) is what usually gets you there. 3. **One public-sector client makes SEF mandatory**, and registration must happen **before** the payment request is submitted (ZEF čl. 2 st. 2). 4. **Voluntary registration binds you for the current plus the following calendar year** (ZEF čl. 5 st. 7–8), and turns you into a private-sector subject who must also receive and store incoming e-invoices (ZEF čl. 2 st. 3). 5. **The separate CRF registration duty was repealed as of 30 April 2022** (ZEF čl. 23); the repeal is partial — the payment deadlines in that law stand, and the register is now fed from the electronic invoice. 6. **E-otpremnice reach private-to-private trade on 1 October 2027** (ZEO čl. 16 st. 8), while sending to the **public** sector has been due since **1 January 2026** (čl. 16 st. 5); a services-only paušalac is outside the law at every stage. 7. **Whether a voluntarily registered non-VAT paušalac must file monthly *evidentiranje obračuna PDV* as a reverse-charge tax debtor is unresolved** — get a written opinion before you register. --- ## Frequently asked questions ### Does a Serbian paušalac have to register on SEF? In most cases no. A paušalac who is not registered for VAT and invoices only private domestic clients is not a subjekt privatnog sektora under ZEF čl. 2 st. 1 t. 3, so the system of elektronske fakture is not compulsory for him (ZEF čl. 3 st. 1, čl. 5 st. 1). The obligation appears only if he registers for VAT, invoices a public-sector body, or signs up voluntarily. Registering voluntarily is what turns an optional system into a legal duty. ### When does SEF become mandatory for a Serbian paušalac? SEF becomes mandatory in three situations. First, when the paušalac registers for VAT, because ZEF čl. 2 st. 1 t. 3 defines a private-sector subject as a VAT payer and čl. 3 and čl. 5 make the system compulsory for one. Second, when he invoices a public-sector body: ZEF čl. 2 st. 2 requires registration before submitting the payment request. Third, when he has already registered voluntarily, which binds him under ZEF čl. 5 st. 7-8. ### What happens if a Serbian paušalac registers on SEF voluntarily? He becomes a dobrovoljni korisnik under ZEF čl. 2 st. 1 t. 4 and is bound to use the system in the current and the following calendar year (ZEF čl. 5 st. 7-8). From then on he is treated as a private-sector subject: every invoice to a counterparty in the system goes through SEF, and he must receive and store incoming electronic invoices (ZEF čl. 2 st. 3). Voluntary registration is therefore a commitment measured in years, not a setting you can switch off. ### Can a Serbian paušalac deregister from SEF at any time? No. There is no notice period to observe, but the statutory lock-in runs for the current plus the following calendar year (ZEF čl. 5 st. 8), so the earliest realistic exit is 1 January of the year after the one in which you registered. Deletion is requested from the Ministry of Finance at cip@mfin.gov.rs under the procedure in the Pravilnik o elektronskom fakturisanju (čl. 34b-34v). Confirm the current procedure on efaktura.gov.rs before you send anything, because that pravilnik is amended every few months. ### Does a Serbian paušalac have to register in the CRF? No. The separate duty to register invoices in the Centralni registar faktura was repealed: ZEF čl. 23 struck the CRF-registration provisions out of the Zakon o rokovima izmirenja novčanih obaveza u komercijalnim transakcijama with effect from 30 April 2022. The repeal is partial, so the payment deadlines in that law still stand; what went is the separate filing and the creditor deadline attached to it. The register itself still exists and is fed from the electronic invoice, so pages that still describe a manual CRF registration are out of date. ### Do e-otpremnice apply to a Serbian paušalac? A paušalac who sells services only is outside the scope of the Zakon o elektronskim otpremnicama (čl. 2 t. 4, čl. 3, čl. 4). That law attaches its obligations to the movement of goods, and a person who is not a VAT payer counts as a subjekt privatnog sektora only where excise goods are involved. If you deliver software, consulting, design or teaching there is no goods movement to document, so no electronic waybill obligation attaches to you at any stage of the rollout. ### When does the e-otpremnica obligation reach private companies in Serbia? The private-to-private stage starts on 1 October 2027, not 1 January 2027 as several accounting blogs state, and the same date governs a private-sector subject's duty to receive an electronic waybill on an ordinary movement of goods. From 1 January 2026 the obligation already covered the public sector, private-sector subjects moving excise goods, and private-sector subjects sending to the public sector. An error-tolerance window ran from 1 January to 30 June 2026, and the separate provisions on the paper-form e-otpremnica apply from 1 April 2026. The governing law is the Zakon o elektronskim otpremnicama, Sl. glasnik RS 94/2024 i 109/2025, član 16. ### What is the penalty if a Serbian paušalac fails to use SEF when required? For a preduzetnik that qualifies as a subjekt privatnog sektora, ZEF čl. 18 sets a fine of 50,000 to 500,000 RSD. The band covers failures such as not issuing an electronic invoice where one is required and not complying with the rules of the system. It bites only someone who is actually inside the scope of the law, which for a paušalac means a VAT payer, a supplier to the public sector, or a dobrovoljni korisnik. ### Does a Serbian paušalac have to do elektronsko evidentiranje obračuna PDV? An unregistered non-VAT paušalac does not. ZEF čl. 4 st. 1, in force since 1 January 2025, places the obligation on a poreski dužnik who is a VAT payer, and on persons outside the VAT system who are either public-sector entities or dobrovoljni korisnici of SEF; the deadline is the 12th of the month following the tax period. Elektronsko evidentiranje prethodnog poreza under ZEF čl. 4a applies only to VAT payers. Whether a voluntarily registered non-VAT paušalac who is a reverse-charge tax debtor is caught remains an open question with no official opinion. ### Does crossing 8,000,000 RSD put a Serbian paušalac into SEF? Indirectly, yes. Crossing 8,000,000 RSD of turnover over the previous 12 months makes you a VAT payer under ZPDV čl. 33 st. 1, and you then have 5 days to file the evidenciona prijava under ZPDV čl. 38 st. 1. Once registered for VAT you are a subjekt privatnog sektora under ZEF čl. 2 st. 1 t. 3, and SEF becomes compulsory. The 6,000,000 RSD paušal limit is a different threshold under a different law and does not by itself put you on SEF. If you invoice clients abroad, the place-of-supply rules that decide what counts toward the 8-million threshold are covered in the [guide to invoicing foreign clients](/articles/foreign-invoicing). --- ## Sources - [Zakon o elektronskom fakturisanju](https://www.efaktura.gov.rs/tekst/9490/zakon-o-elektronskom-fakturisanju-04122025.php) — consolidated text, "Sl. glasnik RS", br. 44/2021, 129/2021, 138/2022, 92/2023, 94/2024 i 109/2025 (čl. 2, čl. 3, čl. 4, čl. 4a, čl. 5, čl. 18, čl. 23) - [Pravilnik o elektronskom fakturisanju](https://www.efaktura.gov.rs/tekst/1906/pravilnik-o-elektronskom-fakturisanju.php) and the [amendments effective 1 August 2026](https://www.efaktura.gov.rs/tekst/10837/pravilnik-o-izmenama-i-dopunama-pef-01082026.php), "Sl. glasnik RS", br. 71/2026 - [Zakon o rokovima izmirenja novčanih obaveza u komercijalnim transakcijama](https://www.efaktura.gov.rs/tekst/408/zakon-o-rokovima-izmirenja-novcanih-obaveza-u-komercijalnim-transakcijama.php) — the law whose CRF-registration articles ZEF čl. 23 repealed - [Elektronsko evidentiranje obračuna PDV u SEF](https://www.efaktura.gov.rs/tekst/4071/elektronsko-evidentiranje-obracuna-pdv-u-sef.php) and [elektronsko evidentiranje prethodnog poreza](https://www.efaktura.gov.rs/tekst/5481/elektronsko-evidentiranje-prethodnog-poreza.php) — Ministry of Finance guidance - [SEF ažuriranja i verzije](https://www.efaktura.gov.rs/tekst/5421/sef-azuriranja-i-verzije.php) — the release log behind the version dates - [Zakon o elektronskim otpremnicama](https://www.paragraf.rs/propisi/zakon-o-elektronskim-otpremnicama.html) — consolidated text, "Sl. glasnik RS", br. 94/2024 i 109/2025 (čl. 1, čl. 2 t. 4, čl. 3, čl. 4, čl. 16, and the samostalni članovi of 109/2025) - [Zakon o porezu na dodatu vrednost](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2004/84/3/reg) — "Sl. glasnik RS", br. 84/2004, with amendments (čl. 33, čl. 38) # KPO Knjiga vs Bank Statement: Why the Two Totals Differ Source: https://preduzmi.com/articles/kpo-vs-bank-statement Published: 2026-07-01, updated 2026-08-21 > Your KPO knjiga and your bank statement measure different things. The eight legitimate reasons the totals differ, why the 6,000,000 RSD limit counts invoices issued rather than payments received, and how to reconcile. *Last updated: August 2026. This guide reflects the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) (consolidated through "Sl. glasnik RS", br. 6/2026), the [Pravilnik o poslovnim knjigama i iskazivanju finansijskog rezultata po sistemu prostog knjigovodstva](https://www.purs.gov.rs/lat/preduzetnici/pregled-propisa/pravilnici/407/pravilnik-o-poslovnim-knjigama-i-iskazivanju-finansijskog-rezultata-po-sistemu-prostog-knjigovodstva.html) ("Sl. glasnik RS", br. 140/2004 i 44/2018 – dr. zakon), and the Poreska uprava's published answer on how total turnover is counted, carried by Paragraf on 29 January 2026.* **In short** - **Neither record is wrong.** The KPO knjiga counts invoices issued; the bank statement counts money that moved. They answer different questions, so they are not supposed to agree. - **The KPO is dated by the business transaction, not by the collection.** The Poreska uprava's published answer of **29 January 2026** puts turnover in the period in which the supply was performed and the transaction was documented by an issued invoice and recorded in the book, *"nezavisno od okolnosti da li je i kada realizovana naplata"*. - **The 6,000,000 RSD limit follows the same basis** — invoices issued, not payments received (ZPDG čl. 40 st. 2 t. 4, read with that answer). Several published guides state the opposite. - **The KPO has no expense side.** Every debit row on your statement is irrelevant to it, because a paušalac deducts nothing (Pravilnik čl. 7). - **Reconcile per invoice, never per total.** Match each KPO row to the credit that settled it, and name the reason for any difference. - **There is no prescribed KPO closing procedure and no statutory closing date.** Pravilnik čl. 13 st. 1 prescribes closing only for the PK-1 book. ## Neither total is wrong **A KPO total and a bank total are not two measurements of the same quantity, so a gap between them is the normal state rather than an error.** The KPO knjiga is a register of invoices issued for your registered activity. The bank statement is a register of money that moved through one account, in both directions, for any reason at all. The two overlap only in the middle: invoices you issued that were paid inside the period you are looking at. Everything outside that overlap is a legitimate difference. The first question is not where the mistake is, but whether one exists. Almost every KPO-versus-bank gap traces to one of the eight causes below. --- ## What the KPO actually holds The KPO knjiga carries one category of data: *prihodi od prodatih proizvoda i izvršenih usluga* — revenue from goods sold and services performed (Pravilnik čl. 7). It is the only business book a paušalac is required to keep (ZPDG čl. 43 st. 4). The prescribed columns are these five: | Column | What goes in it | |---|---| | Redni broj | The sequential entry number, which must also appear on the underlying document | | Datum i opis knjiženja | The entry date and a short description of the transaction | | Prihod od proizvoda | Revenue from goods, in dinars | | Prihod od usluga | Revenue from services, in dinars | | Ukupno | The row total | There is no expense column, no balance, no counterparty field and no account number. **A paušalac deducts nothing** — the standardised cost allowance is already inside the assessed base in your rešenje — so cost data has nowhere to go in this book. Each entry must rest on a *verodostojna knjigovodstvena isprava*, a reliable accounting document (ZPDG čl. 46). The book is kept at the business premises, or at the accounting firm if you outsource it (ZPDG čl. 47), and retained for **at least 5 years** from the last day of the business year (ZPDG čl. 48). For the mechanics of the book itself — storno lines, chronology, electronic format — see [the KPO guide](/articles/kpo-book). --- ## Which date an entry carries **The KPO entry belongs to the period of the business transaction, not to the period of the collection.** The Poreska uprava was asked exactly this and answered in print on 29 January 2026: total turnover in a calendar year is made up of income from the activity realised in that period — *"(periodu kada je izvršen promet dobara i/ili usluga) i kada je ta poslovna promena dokumentovana (izdat račun) i evidentirana u knjizi o ostvarenom prometu, nezavisno od okolnosti da li je i kada realizovana naplata potraživanja po tom osnovu"*. Read the contrast it actually draws: invoice against **collection**, not invoice against supply date. The period is the one in which the supply was performed, *and* documented by an issued invoice, *and* entered in the book. In ordinary service work those fall together, and the date written in the *datum i opis knjiženja* column is the invoice date. An invoice issued on 20 December 2026 and paid on 14 January 2027 is therefore **2026 revenue in the KPO and a 2027 credit on the statement**. Both records are correct, and this is why a December-heavy business shows a KPO total above its bank credits. The mirror case: a January 2026 credit paying a December 2025 invoice belongs to the 2025 KPO and must not be entered again. One caveat on the source. It is a published answer to a press question, not a numbered *mišljenje*, so it carries the tax authority's stated reading rather than the force of a binding act. It is also the only direct statement any authority has made on the point. **A bank total is not a revenue figure** Never test a threshold against your account balance, your annual credits, or a bank-generated turnover report. Those figures include money that is not revenue and exclude revenue that has not been collected. The figure that counts is the KPO total, built from invoices issued. --- ## The 6,000,000 limit is counted on invoices issued **Both statutory thresholds are turnover measures, not cash measures.** | Threshold | Amount | Window | Legal basis | |---|---|---|---| | Paušal status limit | **6,000,000 RSD** | the year preceding the year for which the tax is assessed | ZPDG čl. 40 st. 2 t. 4 | | VAT (PDV) registration | **8,000,000 RSD** | the previous 12 months | ZPDV čl. 33 st. 1 | For the 6,000,000 RSD limit the point is settled by the answer quoted above: the revenue counts in the year the supply was made and the transaction was documented and recorded, whether or not it was ever collected. An unpaid December invoice still consumes headroom, and a January payment for it does not consume headroom twice. That answer addresses the paušal limit specifically. It does not restate the VAT rule, but the practical instruction is the same: check the 8,000,000 RSD threshold against your invoice list rather than your bank credits, and remember that crossing it triggers an *evidenciona prijava* within **5 days** (ZPDV čl. 38 st. 1). The two counts are not built from the same invoices. ZPDV čl. 33 st. 6 limits *ukupan promet* to the supplies in čl. 28 st. 1 t. 1) and 2) — those taxed in Serbia and those exempt with credit under čl. 24 — and leaves out t. 3), a supply performed abroad. A service to a business client established outside Serbia has its place of supply in the client's country (ZPDV čl. 12 st. 4). It generally stays outside the 8,000,000 RSD count while counting in full towards the 6,000,000 RSD one. Čl. 12 sets special rules for particular categories of service, so check an unusual one rather than assuming. Both thresholds are set out in [the revenue-limits guide](/articles/revenue-limits). One category drops out of the 6,000,000 RSD count entirely: income taxed as *drugi prihodi* under ZPDG čl. 85 st. 1 t. 17 after a failed [independence test](/articles/independence-test) does not count towards it (ZPDG čl. 40 st. 5). --- ## Eight reasons the two totals legitimately differ | # | Cause | Where it appears | What to do | |---|---|---|---| | 1 | **Timing** — invoice issued in one year, paid in the next | KPO in year one, statement in year two | Nothing; reconcile the invoice across the year boundary | | 2 | **Unpaid invoices** | KPO only | Nothing to the book. The revenue is already counted | | 3 | **Non-revenue credits** — refunds, a transfer from your own personal account, a loan, a reversed transaction | Statement only | Never enter them. They are not revenue from your activity | | 4 | **Outgoings** — tax, contributions, purchases, transfers out | Statement only | Nothing. The KPO has no expense side | | 5 | **Bank fees deducted from an incoming payment** | Both, at different amounts | The KPO carries the invoiced amount; the net credit is smaller | | 6 | **Foreign-currency conversion** | Both, at different amounts | Nothing. The invoice converts at an official middle rate, the bank at its own rate and value date | | 7 | **Multi-leg bookings** — one payment shown as several ledger legs sharing one reference | Statement only | Take the net of the legs as the payment; do not count each leg | | 8 | **Aggregated payments** — one transfer settling several invoices | One credit, several KPO rows | Split the credit across the invoices it settles | Three deserve more than a table row. **Bank fees (5).** When a correspondent or receiving bank deducts a charge from an incoming payment, the KPO entry is still the amount you invoiced. The fee is a cost, and a paušalac records no costs. The gap between the KPO row and the credit line is therefore permanent and expected; note the fee as the reason for the difference rather than adjusting the book. **Multi-leg bookings (7).** Statements from some Serbian banks present a single incoming SEPA payment as several ledger legs sharing one reference. This is an observation about how statements read, not a legal rule, but taken at face value it either doubles a payment or splits it into fragments matching no invoice. Take the net of the legs sharing a reference as the payment. The export guide for [Raiffeisen XML](/articles/how-to-export-raiffeisen-xml) shows where these appear in the file. **Aggregated payments (8).** A client settling three invoices with one transfer produces one credit against three KPO rows. This is what makes total-versus-total reconciliation fail hardest: the sums can be right while nothing lines up. Preduzmi imports Raiffeisen XML and generic CSV statements, collapses multi-leg SEPA bookings into a single net transaction, and proposes a match between each credit and an open invoice by date and amount; where amounts differ, you record the reason — bank fee, exchange-rate difference, partial payment, rounding. It is not a substitute for an accountant and gives no advice on your situation. --- ## How to reconcile: per invoice, never per total Work from the invoice side, because the invoice list is the record the law measures. 1. **List the KPO rows for the period** — your invoices, in order, with their dinar amounts. 2. **Find the credit that settled each one.** Match on client, amount and reference, not on date alone; the payment date will usually differ from the entry date. 3. **Classify each result.** Matched exactly; matched with a difference you can name (fee, exchange rate, partial payment, rounding); or not yet paid. 4. **Write the reason down for every difference.** A named difference is a reconciled item. An unnamed one resurfaces a year later, when nobody remembers the answer. 5. **Then look at the statement rows nothing matched.** Most of them are not revenue. A leftover credit is one of three things: a non-revenue inflow, which never goes in the KPO; a payment for an invoice recorded in an earlier period, already counted; or a payment for work you invoiced but forgot to enter. Only the third is a KPO problem, and the fix is a new entry with the next redni broj, never an edit to an existing row. --- ## Foreign currency: what the law fixes and what it leaves open **The type of rate is fixed by law; the date is not.** For bookkeeping and statistics the *zvanični srednji kurs* of the National Bank of Serbia applies (ZDP čl. 41 st. 2). Applying the buying rate, the selling rate or the rate your bank used is a *prekršaj*, and for a preduzetnik it carries **150,000 to 500,000 RSD** (ZDP čl. 61 t. 37). Which date's rate a non-VAT paušalac should use is **prescribed nowhere**. The three places you would expect to find the rule do not contain it: - **ZPDV čl. 22** ties conversion to the day the tax liability arises, but it governs the VAT base and binds VAT payers, not a paušalac outside the VAT system. - **The Zakon o računovodstvu** does not reach him: it defines *preduzetnici* as those keeping double-entry books (čl. 2 t. 3), and a paušalac keeps only the KPO. - **The KPO pravilnik** (čl. 7) sets out no recognition basis, no conversion rule and no rate date. The common practice is to convert at the middle rate on the invoice date, or on the supply date where the two differ. **That is practice, not a rule.** The 29 January 2026 answer settles which period the entry falls in; it says nothing about which day's rate converts it. Pick one basis, apply it to every invoice, and keep the rate you used with the invoice. Whichever date you choose, the bank credits you at its own rate on its own value date, and that difference is a *kursna razlika* rather than an error in either record. Incoming foreign payments are covered in [the foreign-currency guide](/articles/foreign-currency-inflows). --- ## What an inspection compares An inspector works with three documents: the KPO, the invoices behind it, and the bank statements for the same period. The KPO-to-invoice tie has to be exact, and the rulebook builds the link in both directions — the redni broj of the entry must also appear on the underlying document (Pravilnik čl. 7). The KPO-to-statement tie is explanatory rather than arithmetic: you are expected to say why a credit differs from an invoice, not to make the annual totals equal. Failing to keep the required books, or to produce them on request, carries a fine of **50,000 to 500,000 RSD for a preduzetnik** (ZPPPA čl. 178b st. 2). ZPDG prescribes no separate offence for the KPO; the sanction runs through ZPPPA. **No closing ritual, no printing routine, no next-day rule** Three administrative obligations that are widely described online do not exist for a paušalac. - **No year-end closing.** Pravilnik čl. 13 st. 1 prescribes closing only for the PK-1 book. Totalling and signing the KPO on 31 December is sensible practice, not a legal step, and there is no statutory closing date. - **No routine printing.** The books may be kept on a data-processing medium so long as they can be printed or displayed on screen on request (Pravilnik čl. 4 st. 1). - **No "enter it by the next day".** ZPDG čl. 45's next-day rule addresses a *preduzetnik poljoprivrednik* and a *preduzetnik drugo lice*. It is repeatedly quoted at paušalci, and it does not apply to them. --- ## Key takeaways 1. **A KPO total and a bank total measure different things**, so a difference is expected and usually needs no correction. 2. **The KPO is dated by the transaction, not by the collection**, per the Poreska uprava's answer of 29 January 2026 — turnover falls in the period in which the supply was performed, documented by an issued invoice and recorded in the book, whether or not it was ever paid. 3. **The 6,000,000 RSD paušal limit counts invoices issued** (ZPDG čl. 40 st. 2 t. 4), so an unpaid December invoice consumes headroom and its January payment does not consume it again. 4. **Non-revenue credits and every debit row belong to the statement alone** — the KPO holds only revenue from goods sold and services performed (Pravilnik čl. 7). 5. **Reconcile invoice by invoice and name every difference**; totals that agree by coincidence hide errors per-invoice matching exposes. 6. **The rate type is fixed and the rate date is not** — the *zvanični srednji kurs* is mandatory (ZDP čl. 41 st. 2, and a preduzetnik applying another rate faces 150,000 to 500,000 RSD under čl. 61 t. 37), while no rule sets the date for a non-VAT paušalac. Converting on the invoice or supply date is practice. 7. **Revenue from foreign business clients counts towards the 6,000,000 RSD limit but generally not towards the 8,000,000 RSD VAT threshold**, because that count covers only supplies taxable in Serbia (ZPDV čl. 33 st. 6, read with čl. 28 st. 1 and čl. 12 st. 4). 8. **Keep the book and its documents for at least 5 years** (ZPDG čl. 48); failing to produce them carries a fine of 50,000 to 500,000 RSD (ZPPPA čl. 178b st. 2). ## Frequently asked questions ### Why does a Serbian paušalac's KPO knjiga total not match the bank statement total? Because the two records measure different things. The KPO knjiga counts invoices issued for the registered activity, while the bank statement counts every movement of money through the account in both directions. Timing differences, unpaid invoices, non-revenue credits, outgoings, bank fees, currency conversion and aggregated payments all produce legitimate gaps. A difference is the normal state, not evidence of an error. ### Does a paušalac record the invoice date or the payment date in the KPO knjiga? The invoice date, not the payment date. A Poreska uprava answer published on 29 January 2026 puts turnover in the period in which the supply was performed, the transaction was documented by an issued invoice, and it was recorded in the book, regardless of whether and when the receivable was collected. The date the client's money lands in the account does not determine the KPO entry. That is why a December invoice paid in January sits in two different years on the two records. ### Is the 6,000,000 RSD paušal limit counted on invoices issued or on payments received? On invoices issued. ZPDG čl. 40 st. 2 t. 4 sets the limit on total turnover in the preceding year, and the Poreska uprava answer of 29 January 2026 confirms that turnover is counted when the transaction is documented and recorded, not when it is collected. An unpaid invoice still consumes your headroom. Several published guides state the opposite, and the tax authority's own answer contradicts them. ### Should a paušalac enter a transfer from a personal account into the KPO knjiga? No. The KPO holds only revenue from goods sold and services performed under the registered activity, as prescribed by čl. 7 of the Pravilnik. Money moved from your own personal account, a loan, a refund from a supplier and a reversed transaction are all credits on the statement that never belong in the book. Recording them inflates your apparent turnover and pushes you artificially towards the revenue limits. ### How does a paušalac reconcile a bank statement with the KPO knjiga? Per invoice, never per total. List the KPO entries for the period, find the credit that settled each one by client, amount and reference rather than by date, then classify each result as matched exactly, matched with a nameable difference, or unpaid. Write down the reason for every difference. Finally, look at the statement rows nothing matched, which are usually non-revenue inflows or payments for invoices already recorded in an earlier period. ### What does a paušalac record in the KPO when the bank deducts a fee from an incoming payment? The invoiced amount, not the net credit. A bank charge is a cost, and a paušalac records no costs in the KPO because the standardised cost allowance is already inside the assessed base in the rešenje. The result is a permanent gap between the KPO row and the credit line, and the correct response is to note the fee as the reason for the difference rather than to adjust the entry. ### Which exchange rate date does a Serbian paušalac use for a foreign-currency invoice in the KPO? The law does not prescribe one. The type of rate is fixed, because the zvanični srednji kurs of the National Bank of Serbia applies for bookkeeping and statistics under ZDP čl. 41 st. 2 and applying a different rate is a prekršaj. No rule sets the date for a non-VAT paušalac: the VAT law's conversion rule binds VAT payers, the accounting law covers only entrepreneurs keeping double-entry books, and the KPO pravilnik prescribes no conversion rule at all. Common practice is the middle rate on the invoice or supply date, which is practice rather than law, so choose one basis, apply it consistently, and keep the rate you used together with the invoice. ### Does a paušalac have to enter unpaid invoices in the KPO knjiga? Yes. The entry follows the transaction and its invoice, not the collection, so an invoice that is never paid is still recorded and still counts towards the 6,000,000 RSD limit. This is the main reason a KPO total can legitimately exceed the money that reached the bank account. If the invoice is later cancelled, the correction is a storno line with the next sequential number, never an edit to the original row. ### Is there a deadline for a paušalac to enter an invoice in the KPO knjiga? No per-entry deadline applies to the KPO. The often-quoted rule requiring an entry by the following day comes from ZPDG čl. 45, which is addressed to a preduzetnik poljoprivrednik and a preduzetnik drugo lice, not to a paušalac. Entries must still be sequential, documented by a reliable accounting document under ZPDG čl. 46, and available when the tax authority asks for them. ### Does a paušalac have to close and print the KPO knjiga at the end of the year? No. There is no prescribed closing procedure and no statutory closing date for the KPO, because čl. 13 st. 1 of the Pravilnik prescribes closing only for the PK-1 book. Totalling and signing at 31 December is sensible practice rather than a legal requirement. Printing is not routinely required either, since the book may be kept on a data-processing medium provided it can be printed or displayed on screen on request. ## Sources - [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) — čl. 40, 43, 45, 46, 47, 48 and 85 ("Sl. glasnik RS", consolidated through br. 6/2026) - [Pravilnik o poslovnim knjigama i iskazivanju finansijskog rezultata po sistemu prostog knjigovodstva](https://www.purs.gov.rs/lat/preduzetnici/pregled-propisa/pravilnici/407/pravilnik-o-poslovnim-knjigama-i-iskazivanju-finansijskog-rezultata-po-sistemu-prostog-knjigovodstva.html) — čl. 4, 7 and 13 ("Sl. glasnik RS", br. 140/2004 i 44/2018 – dr. zakon) - [Poreska uprava's answer on how total turnover is counted, published 29 January 2026](https://www.paragraf.rs/dnevne-vesti/290126/290126-vest11.html) — carried by Paragraf from Biznis i finansije, 27 January 2026 - [Zakon o porezu na dodatu vrednost](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2004/84/3/reg) — čl. 12 st. 4, čl. 22, čl. 28 st. 1, čl. 33 and čl. 38 - [Zakon o deviznom poslovanju](https://www.paragraf.rs/propisi/zakon_o_deviznom_poslovanju.html) — čl. 41 st. 2 (zvanični srednji kurs) and čl. 61 t. 37 (the prekršaj for applying another rate) - [Poreska uprava — Preduzetnici paušalci](https://www.purs.gov.rs/preduzetnici-pausalci.html) - [Narodna banka Srbije — zvanični srednji kurs](https://webappcenter.nbs.rs/ExchangeRateWebApp/ExchangeRate/CurrentMiddleRate) # Serbian Paušal Tax Base: How It Is Calculated, and When Municipality Matters Source: https://preduzmi.com/articles/pausal-tax-base Published: 2026-06-23, updated 2026-08-21 > The exact formula behind the Serbian paušal tax base — activity coefficient, municipality data, correction coefficients, the 10% annual cap — and why for activity code 6201 the municipality is not an input at all. *Last updated: August 2026. Reflects the [Uredba o paušalnom oporezivanju](https://www.purs.gov.rs/preduzetnici/pregled-propisa/uredbe/6095/uredba-o-blizim-uslovima-kriterijumima-i-elementima-za-pausalno-oporezivanje-obveznika-poreza-na-prihode-od-samostalne-delatnosti.html) ("Sl. glasnik RS", br. 94/2019, with amendments through 115/2025), the [ZPDG](https://www.purs.gov.rs/preduzetnici/pregled-propisa/zakoni/9941/zakon-o-porezu-na-dohodak-gradjana.html) and the [ZDOSO](https://www.purs.gov.rs/preduzetnici/pregled-propisa/zakoni/9461/zakon-o-doprinosima-za-obavezno-socijalno-osiguranje.html).* **In short** - **The formula:** average monthly salary in your municipality over the last 12 months × employees there × your koeficijent delatnosti ÷ population there — **Uredba čl. 4 st. 2**. Not "a percentage of the average salary", which is how it is almost always described. - **For 15 activity codes, Republic-level figures replace the local ones** (Uredba čl. 4 st. 4). **6201** and **6202** are on that list, so for a programmer the municipality does not affect the base at all. - **The zone coefficient** (Uredba čl. 5 t. 1, multipliers 1.1 down to 0.7) reaches only a closed list of codes. **6201 is not among them.** - **The koeficijent delatnosti for 6201 and 6202 is 4.025** (Uredba Prilog 1, column "2023. god. i dalje"). - **Increases are capped at 10% a year** through 2027 — except where the increase follows a change of activity code, municipality or location (Uredba čl. 6 st. 1–2). - **The assessed base carries 45.05%:** 10% income tax (ZPDG čl. 38) plus 35.05% contributions (ZDOSO čl. 44 st. 1). Almost every explanation of the paušal system says the base is "a percentage of the average salary in your municipality". That is not what the Uredba says, and the difference is not academic. It is why a widely-sold piece of advice — register the seat in a cheaper municipality, or at a coworking address, and the tax will fall — does not work for a paušalac registered under one of the IT activity codes. --- ## What the rešenje assesses **Your paušal obligation is not a share of what you invoice. It is a percentage of an assessed income figure — the *paušalno utvrđen prihod* — that the Poreska uprava calculates and states in your annual *rešenje*** (ZPDG čl. 33 st. 1 i st. 3). Revenue enters the system in exactly one place: eligibility. Cross 6,000,000 RSD of turnover in the previous year and the right to paušal taxation ends (ZPDG čl. 40 st. 2 t. 4). Below that line, invoicing 200,000 RSD in a month and invoicing nothing produce the identical obligation. See [the guide to the 6M and 8M limits](/articles/revenue-limits) for how that threshold is counted. What drives everything else is your **pretežna delatnost** — the activity registered with APR, or, where that is not the one earning the money, the activity that generated more income (ZPDG čl. 41 st. 1–2). Every code carries its own coefficient in **Prilog 1** of the Uredba, a table of 407 rows. --- ## The formula behind the polazna osnovica Uredba čl. 4 st. 2 prescribes the starting base directly: **Polazna osnovica = (average monthly salary in the municipality over the last 12 months × number of employees in that municipality × koeficijent delatnosti) ÷ population of that municipality** Four inputs, three of which have nothing to do with you personally. The **average monthly salary**, the **number of registered employees** and the **population** all come from Republički zavod za statistiku and describe the municipality of your seat, not you. Only the **koeficijent delatnosti** tracks the individual taxpayer, and only through the registered activity code. Note what the formula does: dividing an employment-weighted salary figure by population produces a per-capita measure, not a salary. That is why the shorthand misleads — a municipality with a high average wage but a large population and few registered employees does not behave the way it predicts. One geographic special case. **For a seat in one of the ten core Belgrade municipalities, the sums across all of them are used, divided by their combined population** (Uredba čl. 4 st. 3). Central Belgrade is one unit, not ten. --- ## The 15 codes that use Republic-level figures instead **Uredba čl. 4 st. 4 replaces the local salary, employment and population figures with Republic-level ones for a fixed list of activity codes.** For a taxpayer on that list, the municipality of the seat is not an input to the formula at all. | Šifra | Activity (short) | |---|---| | 4932 | Taxi transport | | 4939 | Other passenger land transport | | 5911 | Film and video production | | **6201** | **Computer programming** | | **6202** | **IT consulting** | | 6209 | Other IT services | | 6311 | Data processing and hosting | | 6312 | Web portals | | 6399 | Other information service activities | | 7022 | Business and management consulting | | 7111 | Architectural activities | | 7112 | Engineering and technical consulting | | 7410 | Specialised design activities | | 9001 | Performing arts | | 9002 | Support activities to performing arts | Every other activity code uses the figures of the municipality where the seat sits. --- ## Koeficijent delatnosti by šifra The coefficient is the one input your registration choice sets. These are the values in the **"2023. god. i dalje"** column of Uredba Prilog 1: | Šifra | Activity | Koeficijent | |---|---|---| | 6201 | Računarsko programiranje | **4.025** | | 6202 | IT consulting | **4.025** | | 8621 | General medical practice | 3.536 | | 7112 | Engineering and technical consulting | 2.897 | | 6311 | Data processing and hosting | 2.870 | | 7022 | Business and management consulting | 2.816 | | 7111 | Architectural activities | 2.730 | | 6209 | Other IT services | 2.688 | | 7410 | Specialised design activities | 2.682 | | 6399 | Other information service activities | 2.530 | | 6910 | Legal activities | 2.102 | | 7420 | Photographic activities | 2.080 | | 9602 | Hairdressing and beauty treatment | 1.941 | | 4932 | Taxi transport | 1.244 | Programming and IT consulting carry the highest coefficients of the codes listed above. That is the single largest reason an IT paušalac's assessment differs from a photographer's. The full table runs to 407 rows, so check your own šifra against Prilog 1 rather than inferring it from this sample. --- ## The correction coefficients Once the polazna osnovica exists, Uredba čl. 5 applies multipliers to it. The Poreska uprava applies them from registry data; they are not something you claim. | Coefficient | Value | Legal basis | |---|---|---| | Zone (location within the municipality) | 1.1 down to 0.7 | čl. 5 t. 1 — **listed codes only** | | Time since registration: year of registration / up to 12 months / over 12–24 / over 24–36 / over 36 | **0.5** / 0.8 / 0.85 / 0.9 / 1.0 | čl. 5 t. 2 | | Under 30 or over 55 years of age | 0.9 | čl. 5 t. 3 | | Under 30 or over 60 in codes 6910, 711x, 7500, 862x, 8690 | 0.7 | čl. 5 t. 3 | | Disability | 0.85 | čl. 5 t. 3 | | More than 90 days of maternity or child-care absence | 0.85 | čl. 5 t. 3 | | Certified stari i umetnički zanati | 0.5 | čl. 5 t. 4 | Two limits sit on top of this. **The cumulative product of the correction coefficients cannot fall below 0.5** (Uredba čl. 5 st. 2), so stacking several does not compound indefinitely. And **none of them apply to code 4932** (Uredba čl. 5 st. 3). The registration ladder carries its own exception in čl. 5 t. 2: the reduced coefficient does not apply where the person was registered as a preduzetnik less than 18 months earlier. Closing and re-registering does not reset the ladder. The zone coefficient applies only to the codes listed in čl. 5 t. 1: **1071, 1512, 1814, 3314, 5610, 7420, 8211, 8219, the 862 and 869 groups, 9329, the 95 group, 9601, 9602 and 9604.** Bakeries, restaurants, photographers, hairdressers, medical and dental practices, repair shops. Not software. --- ## Why a cheaper opština does not lower an IT paušalac's base **For activity codes 6201 and 6202, registering the seat in a cheaper municipality — or at a coworking address marketed for that purpose — does not change the paušal base.** Two articles would have to be open for the address to matter; for these codes both are closed. - **Uredba čl. 4 st. 4** puts 6201 and 6202 on the Republic-level list, so the local salary, employment and population inputs are never read and the municipality is not in the formula. - **Uredba čl. 5 t. 1** limits the zone coefficient to the codes listed above. 6201 and 6202 are not on that list, so location within a municipality does not reach the base either. The two lists do not overlap. Every code using Republic-level data also sits outside the zone list, so geography resolves the same way for all fifteen. **"Register at our address" is sold as a tax benefit** It is a real variable for some activities and inert for others, and the difference is set by two articles of the Uredba, not by the provider. For a bakery (1071), a restaurant (5610), a photographer (7420) or a hairdresser (9602), municipality and zone genuinely enter the calculation. For a programmer under 6201, they do not. Check your own šifra against čl. 4 st. 4 and čl. 5 t. 1 first. A moved seat is not consequence-free, either. It changes which lokalna poreska administracija handles your [eko taksa](/articles/eko-taksa), and — as the next section explains — it removes the protection of the 10% cap. --- ## The 10% cap, and why the paušal went up **Uredba čl. 6 st. 1 caps year-on-year increases of the paušal base at 10%, applied until the correct level is reached, through 2027.** Where the formula would produce a larger jump, the assessment climbs in 10% steps instead. **Uredba čl. 6 st. 2 removes the cap where the increase results from a change of activity code, municipality or business location** — that taxpayer is recalculated at the full new figure in one step, with no smoothing. An increase in this year's rešenje usually comes from one of four places: 1. **The 10% step**, where the assessment is still climbing toward the level the formula gives (čl. 6 st. 1). 2. **A change of activity code, municipality or location**, which lifts the cap entirely (čl. 6 st. 2). 3. **The registration ladder advancing** — 0.5 to 0.8 after the first calendar year, then 0.85, 0.9 and 1.0 (čl. 5 t. 2). 4. **Updated statistical inputs**, since salary, employment and population figures are refreshed annually. If none of these explains the figure, the assessment can be challenged — the appeal deadline is **15 days** from receipt of the tax act (ZPPPA čl. 142), and electronic delivery counts as receipt on the day the act is posted to the portal, whether or not you opened it (ZPPPA čl. 36). [Reading and contesting the rešenje](/articles/pausal-tax-decision) is covered separately. --- ## What is applied to the base The base is assessed once; two obligations run off it. | Component | Rate | Legal basis | |---|---|---| | Porez na prihode od samostalne delatnosti | **10%** | ZPDG čl. 38 | | PIO (pension) | 24% | ZDOSO čl. 44 st. 1 t. 1 | | Zdravstveno osiguranje (health) | 10.3% | ZDOSO čl. 44 st. 1 t. 2 | | Osiguranje za slučaj nezaposlenosti | 0.75% | ZDOSO čl. 44 st. 1 t. 3 | | **Contributions, total** | **35.05%** | ZDOSO čl. 44 st. 1 | | **Everything, total** | **45.05%** | — | The contribution base for a paušalac is the same paušalno utvrđen prihod, not a separate figure (ZDOSO čl. 22 st. 3). And there is **no neoporezivi iznos** — the full assessed amount is due in a month with no income at all. **35.05%, not 35.5%** The figures **35.5%** and **45.5%** circulate widely, including in at least one popular online paušal calculator. ZDOSO čl. 44 st. 1 gives 24 + 10.3 + 0.75 = **35.05%**, and with the 10% tax from ZPDG čl. 38 the total is **45.05%**. The half-point gap is small, but it makes every reconciliation against your rešenje fail. Both obligations fall due **within 15 days of the end of each month** (ZPDG čl. 110 t. 1; ZDOSO čl. 60 st. 1 defers to that deadline). [The guide to paying your paušal taxes](/articles/tax-payments) covers account numbers and reference formats — verify those against your own rešenje, and against your bank's own payment form, before paying. --- ## Where to find your own figure **Two sources are authoritative: your rešenje, and the official calculator.** - **Your annual *rešenje*** states the paušalno utvrđen prihod and the resulting monthly amounts, and arrives electronically in the ePorezi tax mailbox. - **The official calculator** at [eporezi.purs.gov.rs](https://eporezi.purs.gov.rs/kalkulator-pausalnog-poreza-i-doprinosa.html) computes the amounts from the current inputs. Per-code monthly dinar figures published on commercial sites — "62.01 costs X per month" — should be treated with care. They cannot account for the individual correction coefficients in čl. 5, and at least one such source publishes them alongside the claim that the base is uniform nationwide. That claim holds only for the fifteen codes in čl. 4 st. 4. If the regime itself is still an open question, [the paušalac-versus-knjigaš comparison](/articles/pausalac-vs-knjigash) sets it against full bookkeeping, and [the registration guide](/articles/registering-as-pausalac) covers how the election is made. For a contested assessment or a borderline classification, talk to an accountant. Preduzmi tracks what you owe and when; it does not give tax advice. --- ## Key takeaways 1. The polazna osnovica is the municipal average salary over 12 months, times employees there, times your koeficijent delatnosti, divided by population — Uredba čl. 4 st. 2, not a percentage of the average salary. 2. For 15 activity codes, including **6201 and 6202**, Republic-level figures replace the local ones (Uredba čl. 4 st. 4), so the municipality of the seat is not an input at all. 3. The zone coefficient (Uredba čl. 5 t. 1) reaches only a closed list of codes, and **6201 is not on it**. 4. The koeficijent delatnosti for **6201 and 6202 is 4.025** (Uredba Prilog 1, "2023. god. i dalje"). 5. Correction coefficients for time since registration, age, disability and parental absence multiply the base down, but their cumulative product **cannot fall below 0.5** (Uredba čl. 5 st. 2). 6. Increases are capped at **10% per year** through 2027, except where they follow a change of activity code, municipality or location (Uredba čl. 6 st. 1–2). 7. The assessed base carries **10%** income tax (ZPDG čl. 38) and **35.05%** contributions (ZDOSO čl. 44 st. 1), for **45.05%** in total. --- ## Frequently asked questions ### How is the paušal tax base calculated in Serbia? The starting base (polazna osnovica) is the average monthly salary paid in the municipality of the business seat over the previous 12 months, multiplied by the number of employees in that municipality, multiplied by the activity coefficient for the registered šifra delatnosti, and divided by that municipality's population (Uredba čl. 4 st. 2). The result is then adjusted by correction coefficients for zone, time since registration, age and working capacity (Uredba čl. 5). It is not a simple percentage of the average salary, which is how it is usually described. ### Does a Serbian paušalac pay less tax by registering in a cheaper opština? For fifteen activity codes it makes no difference at all. Uredba čl. 4 st. 4 replaces the local salary, employment and population figures with Republic-level ones for codes 4932, 4939, 5911, 6201, 6202, 6209, 6311, 6312, 6399, 7022, 7111, 7112, 7410, 9001 and 9002, and the zone coefficient in čl. 5 t. 1 does not reach any of them either. For a programmer registered under 6201, the municipality of the seat is not an input to the calculation. For codes that are on the zone list, such as 5610, 7420 or 9602, the location genuinely does affect the base. ### What is the activity coefficient for šifra 6201 in Serbia? The koeficijent delatnosti for 6201, računarsko programiranje, is 4.025 in the "2023. god. i dalje" column of Uredba Prilog 1. The same 4.025 applies to 6202, IT consulting. The coefficient is one factor in the formula rather than the tax itself, so it cannot be converted into a monthly amount on its own. ### Why did my paušal tax increase this year in Serbia? Uredba čl. 6 st. 1 caps annual increases of the paušal base at 10% per year through 2027, until the correct level is reached, so most increases arrive in 10% steps. Uredba čl. 6 st. 2 removes that cap where the increase follows a change of activity code, municipality or business location. A taxpayer past the first calendar year also moves up the registration ladder in čl. 5 t. 2, and the statistical inputs to the formula are refreshed annually. ### What coefficient applies to a Serbian paušalac in the year of registration? Uredba čl. 5 t. 2 sets the coefficient at 0.5 for the calendar year in which the entrepreneur registers. It then steps to 0.8 for up to 12 months of registration, 0.85 for more than 12 up to 24 months, 0.9 for more than 24 up to 36 months, and 1.0 after 36 months. The same tačka excludes the reduction where the person was registered as a preduzetnik less than 18 months earlier, so closing and re-registering does not reset the ladder. ### Is the contribution rate for a Serbian paušalac 35.05% or 35.5%? It is 35.05%. ZDOSO čl. 44 st. 1 sets PIO at 24%, health insurance at 10.3% and unemployment insurance at 0.75%, which sums to 35.05%. Adding the 10% income tax from ZPDG čl. 38 gives a total of 45.05% of the assessed base. The figures 35.5% and 45.5% circulate widely, including in at least one popular online calculator, and they do not match the statute. ### Can correction coefficients reduce a Serbian paušalac's base below half? No. Uredba čl. 5 st. 2 caps the cumulative effect of the correction coefficients so that their product cannot fall below 0.5, however many of them apply at once. Uredba čl. 5 st. 3 separately excludes activity code 4932, taxi transport, from these coefficients entirely. ### How does a Serbian paušalac find the exact amount of the paušal base? There are two authoritative sources. The first is the annual rešenje from the Poreska uprava, which states the paušalno utvrđen prihod and the resulting monthly amounts and is delivered into the ePorezi tax mailbox. The second is the official calculator published by the Poreska uprava at eporezi.purs.gov.rs. Per-code monthly figures published on commercial sites are not a substitute, because they cannot account for the individual correction coefficients in Uredba čl. 5. ### Does a Serbian paušalac's revenue affect the paušal tax base? No. The base is produced by the formula in Uredba čl. 4 and čl. 5, and revenue is not one of its inputs, so the same amount is due in a month with no invoices at all. Revenue matters for eligibility instead: turnover above 6,000,000 RSD in the previous year ends the right to paušal taxation under ZPDG čl. 40 st. 2 t. 4. There is also no tax-free allowance for a paušalac. ### Which activity codes does the zone coefficient apply to in Serbia? Uredba čl. 5 t. 1 applies zone multipliers from 1.1 down to 0.7 to a closed list of codes: 1071, 1512, 1814, 3314, 5610, 7420, 8211, 8219, the 862 and 869 groups, 9329, the 95 group, 9601, 9602 and 9604. Codes outside that list, including 6201 and 6202, are not affected by the zone coefficient at all. --- ## Sources - [Uredba o bližim uslovima, kriterijumima i elementima za paušalno oporezivanje obveznika poreza na prihode od samostalne delatnosti](https://www.purs.gov.rs/preduzetnici/pregled-propisa/uredbe/6095/uredba-o-blizim-uslovima-kriterijumima-i-elementima-za-pausalno-oporezivanje-obveznika-poreza-na-prihode-od-samostalne-delatnosti.html) — "Sl. glasnik RS", br. 94/2019, 96/2019 – ispr., 156/2020, 141/2022, 89/2023, 115/2025; the last amendment was published on 19 December 2025. Articles 4, 5 and 6, and Prilog 1. - [Zakon o porezu na dohodak građana (ZPDG)](https://www.purs.gov.rs/preduzetnici/pregled-propisa/zakoni/9941/zakon-o-porezu-na-dohodak-gradjana.html) — čl. 33, čl. 38, čl. 40, čl. 41, čl. 110. - [Zakon o doprinosima za obavezno socijalno osiguranje (ZDOSO)](https://www.purs.gov.rs/preduzetnici/pregled-propisa/zakoni/9461/zakon-o-doprinosima-za-obavezno-socijalno-osiguranje.html) — čl. 22 st. 3, čl. 44 st. 1, čl. 60 st. 1. - [Kalkulator paušalnog poreza i doprinosa, Poreska uprava](https://eporezi.purs.gov.rs/kalkulator-pausalnog-poreza-i-doprinosa.html) — the official calculator. - [Preduzetnici paušalci, Poreska uprava](https://www.purs.gov.rs/preduzetnici-pausalci.html) — the tax authority's landing page for paušalci. # Late Paušal Tax Payment in Serbia: Interest, Penalties, and Enforced Collection Source: https://preduzmi.com/articles/late-payment-interest Published: 2026-06-11, updated 2026-08-21 > What happens when a paušalac pays the monthly tax late in Serbia: the ZPPPA interest formula (NBS reference rate + 10 points), why the widely quoted +8 points is a different rate, and how enforced collection escalates. *Last updated: August 2026. Reflects the [Zakon o poreskom postupku i poreskoj administraciji](https://www.paragraf.rs/propisi/zakon_o_poreskom_postupku_i_poreskoj_administraciji.html) (ZPPPA), the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) (ZPDG, consolidated through "Sl. glasnik RS", br. 6/2026) and the Zakon o doprinosima za obavezno socijalno osiguranje (ZDOSO). The NBS reference rate quoted below is the rate published on nbs.rs on 21 August 2026.* **In short** - **Interest on late tax is the NBS *referentna kamatna stopa* plus 10 percentage points** — ZPPPA čl. 75 st. 1–4. At the 5.75% reference rate published in August 2026, that is **15.75% per year**. - **The "+8 percentage points" figure repeated all over the Serbian web is the civil *zatezna kamata* — 13.75%.** Different debt, different law. It does not apply to tax. - The interest is **simple**, runs **from the day after the due date**, and is charged **per calendar day** against a 365-day year (366 in a leap year). - **The monthly obligation falls due within 15 days of the end of each month** (ZPDG čl. 110 t. 1); the contributions share that deadline (ZDOSO čl. 60 st. 1). - **A month with no income changes nothing.** A paušalac has no tax-free allowance (ZPDG čl. 38; ZDOSO čl. 22 st. 3), so the assessed amount is due anyway. - An unpaid balance escalates: **5-day *opomena* → *rešenje o prinudnoj naplati* → debt increased by 5% → collection costs of 5%**, with a preduzetnik answering from personal assets. That ladder is cross-checked from practitioner sources, not quoted from the statute. --- ## The date the interest clock starts from **The monthly paušal obligation is due within 15 days of the end of the month it covers** (ZPDG čl. 110 t. 1). The social contributions attach to that same date, because ZDOSO čl. 60 st. 1 defers to the ZPDG deadline. In ordinary months that means the 15th. Where the 15th falls on a weekend or a public holiday, the due date moves to the next working day: in 2026, the January obligation fell due on **18 February**, because of the February holidays. Poreska uprava began delivering the 2026 *rešenja* into the ePorezi tax mailbox on **19 January 2026**. Interest begins on the day after the due date, not on the 15th itself and not at the end of the month. The mechanics of the four separate transfers — accounts, model 97, the BOP from your *rešenje* — are covered in [how to pay your paušal taxes](/articles/tax-payments). --- ## A quiet month does not pause anything **A paušalac owes the full assessed amount in a month with no invoices at all.** There is no *neoporezivi iznos* in this regime. The tax is 10% of the lump-sum income determined in your *rešenje* (ZPDG čl. 38), and the contribution base is that same assessed figure — *"za preduzetnike koji porez plaćaju na paušalno utvrđeni prihod osnovica doprinosa je paušalno utvrđen prihod"* (ZDOSO čl. 22 st. 3). Neither figure is derived from what you actually invoiced this month. This is the point readers most often get wrong before they get the interest question wrong. The obligation runs off the [tax decision](/articles/pausal-tax-decision), not off your turnover, so a slow quarter produces exactly the same monthly amount and exactly the same interest exposure if it goes unpaid. --- ## The interest rate: reference rate plus ten points **Late-payment interest on tax is the NBS reference rate plus 10 percentage points** (ZPPPA čl. 75 st. 1–4). At the reference rate of **5.75%** published by the National Bank of Serbia in August 2026, the annual tax interest rate is **15.75%**. The figure circulating in most blog posts, forum answers and AI-generated summaries is **13.75%** — the reference rate plus 8 points. That is the civil *zatezna kamata*, the default interest on unpaid money debts between private parties. It is a real rate under a real law; it is simply not the rate the Poreska uprava charges you. | Debt | Formula | Rate at a 5.75% reference rate | Legal basis | |---|---|---|---| | Tax and other public revenues owed to the state | reference rate **+ 10 percentage points** | **15.75% per year** | ZPPPA čl. 75 st. 1–4 | | Civil money debts — an unpaid invoice between two businesses | reference rate **+ 8 percentage points** | **13.75% per year** | a separate default-interest statute, not ZPPPA | **Year-stamp the rate, not the formula** The **formula** is fixed by ZPPPA čl. 75 — reference rate plus 10 points. The **rate** is a monetary-policy decision that changes several times in some years. 15.75% is what the formula produces at the 5.75% reference rate in force in August 2026. Any page that quotes a percentage without naming the reference rate and the date behind it is quoting a number with a shelf life. --- ## How the interest is computed ZPPPA čl. 75 st. 1–4 also fixes the arithmetic, and it is simpler than most people expect: - **Simple interest.** No compounding within a period. - **Per calendar day**, against a 365-day year — 366 in a leap year. - **From the day after the due date** until the day the debt is settled. - **On the unpaid balance of each obligation**, so a partial payment reduces what the interest runs on from that day forward. Applying that to a round number: a balance of **20,000 RSD** left unpaid for **30 days** at 15.75% produces 20,000 × 0.1575 × 30 ÷ 365 ≈ **259 RSD** of interest. That is arithmetic on the statutory formula, offered to show the shape of the calculation. **The figure that counts is the one the Poreska uprava books on your taxpayer card**, which reflects the exact days, the exact balances and any reference-rate change inside the period. --- ## Checking what you actually owe **The authoritative record of your debt is the *stanje na poreskoj kartici* on the ePorezi portal.** It lists each obligation, the payments booked against it, and any interest assessed. To reach it you need a *kvalifikovani elektronski sertifikat* or an eID account, the same credentials you use to receive your *rešenje*. Menu labels on the portal change from time to time; the item you want is the taxpayer-card view. Two things regularly surprise people who open the card for the first time. A payment made with last year's BOP may sit unallocated, so an obligation reads as unpaid even though the money left your account — that is a *preknjižavanje* case, described in [how to pay your paušal taxes](/articles/tax-payments). And interest may appear as a separate small line rather than being folded into the principal. --- ## Interest and a fine are two different things **Interest is automatic; a fine is not.** Interest is arithmetic that runs the moment a due date passes. A monetary penalty is a *prekršaj* outcome that arises through a control procedure, and it is not a surcharge that attaches to every late payment. | Situation | Consequence | Where it comes from | |---|---|---| | Obligation assessed, tax simply unpaid | daily interest at the reference rate + 10 points | ZPPPA čl. 75 st. 1–4 (verified) | | Tax determined in a control after non-payment | **10%–50% of the tax determined**, minimum **50,000 RSD** for a preduzetnik | cross-checked practitioner sources, not a statute quote | | Not keeping the KPO knjiga, or not producing it on request | **50,000–500,000 RSD** for a preduzetnik | ZPPPA čl. 178b st. 2 (verified) | The KPO line deserves a note, because it catches people who assumed the bookkeeping rule and the payment rule live in the same law. They do not. ZPDG contains no *prekršaj* for failing to keep the KPO — the sanction runs entirely through ZPPPA čl. 178b st. 2, and the same range covers failing to produce the book when the inspector asks for it. What belongs in the book, and what does not, is in [the KPO knjiga guide](/articles/kpo-book). --- ## The enforced-collection ladder **Enforced collection (*prinudna naplata*) is a sequence, not a single event.** Serbian practitioner sources describe it consistently in these steps: 1. An ***opomena*** — a warning notice giving **five days** to settle the debt voluntarily. 2. A ***rešenje o prinudnoj naplati*** if the deadline passes. 3. The debt is **increased by 5%**. 4. **Collection costs of 5%** are added on top. 5. Because a preduzetnik is not a separate legal person, the debt is ultimately answered for **with personal assets**. This ladder is **cross-checked** across independent Serbian legal-practice sources rather than quoted from a numbered article, and it is presented that way deliberately: the article numbers governing each step were not verified for this guide. The same caveat applies to the question people actually search for — a *blokada računa*. A blocked account is an outcome of enforced collection, not its first move: the *rešenje* is executed against the taxpayer's funds and assets, and the money in a business account is the most reachable of those. Treat that as reported practice. If you want to know where you stand, the taxpayer card on ePorezi answers it directly, and the [compliance calendar](/articles/calendar-checklist) keeps the due dates from arriving unannounced. **An appeal does not stop any of this.** ZPPPA čl. 147 st. 1 is flat: *"Žalba ne odlaže izvršenje poreskog upravnog akta."* The obligation stays due and the interest keeps running while a *žalba* is pending. Under čl. 147 st. 2 the second-instance body **may** postpone execution, but only where the taxpayer documents that paying before the act becomes final would cause substantial economic harm. That is a reasoned exception you have to ask for and evidence, not something an appeal triggers on its own. --- ## What the record does not settle Three gaps are worth naming, because filling them with a plausible guess is how bad advice spreads. **No statutory deadline for issuing the annual *rešenje*.** No source consulted for this guide identified a rule fixing when the Poreska uprava must issue it. What is documented is the 2026 practice: delivery into the ePorezi mailbox started 19 January 2026 and the first payment fell due 18 February 2026. A date observed once is not a rule. **Electronic delivery is deemed service.** A tax act *"smatra se dostavljenim danom postavljanja na portal Poreske uprave"* (ZPPPA čl. 36), and the same article removes the need for separate consent from anyone who already files tax returns electronically. The practical consequence: the **15-day appeal window** (ZPPPA čl. 142, 143) runs from the day the document was posted, whether or not you logged in to read it. **The appeal fee is not stated here.** The amount reported in circulation comes from a source that predates subsequent revisions of the administrative-fee schedule. Check the current *taksa* with Poreska uprava before filing rather than relying on a figure from a blog. --- ## If a payment has already been missed The procedure is short, and none of it involves negotiating anything. 1. **Pay the outstanding obligation** using the account, model and BOP from your current *rešenje*. Interest runs per day on the balance, so the balance is what closes it. 2. **Open the taxpayer card on ePorezi** and confirm the payment was booked against the right obligation. A correct total paid to the wrong reference does not clear the debt. 3. **If interest has been assessed**, it appears as its own line and is settled the same way as the principal. 4. **If a payment was misallocated**, file a *zahtev za preknjižavanje* with your Poreska uprava office rather than paying twice. 5. **If an *opomena* has already arrived**, the five-day window on it is the one that matters — the ladder above starts moving after it lapses. **Verify every payment detail against your own *rešenje*** Account numbers, the BOP and the amounts are individual to you and change with each annual *rešenje*. Check every field against your own decision, and against your bank's own payment form, before you send the transfer. Preduzmi tracks the obligations and their dates; it does not replace your *rešenje* as the source of the payment details, and it is not a substitute for an accountant where a control procedure or an appeal is already under way. --- ## Key takeaways 1. **Late-payment interest on tax is the NBS reference rate plus 10 percentage points** under ZPPPA čl. 75 st. 1–4 — **15.75% per year** at the 5.75% reference rate in force in August 2026. 2. **The 13.75% figure so widely quoted is the civil *zatezna kamata*** (reference rate + 8 points) and belongs to a different law and a different kind of debt. 3. **Interest is simple, daily, and runs from the day after the due date** against a 365- or 366-day year, on the unpaid balance of each obligation. 4. **The monthly obligation is due within 15 days of the end of each month** (ZPDG čl. 110 t. 1; ZDOSO čl. 60 st. 1), shifted for weekends and holidays — the January 2026 obligation fell due on 18 February 2026. 5. **A month with zero income still carries the full assessed amount**, because a paušalac has no tax-free allowance (ZPDG čl. 38; ZDOSO čl. 22 st. 3). 6. **A fine is separate from interest**: 10%–50% of the tax determined in control with a 50,000 RSD minimum for a preduzetnik is a cross-checked figure tied to a control procedure, while failing to keep the KPO knjiga carries 50,000–500,000 RSD under ZPPPA čl. 178b st. 2. 7. **Enforced collection escalates in fixed steps** — five-day *opomena*, *rešenje*, debt +5%, costs +5%, then personal assets — and the taxpayer card on ePorezi is where you see it coming. 8. **An appeal does not suspend payment** (ZPPPA čl. 147 st. 1). Only the second-instance body can postpone execution, and only where the taxpayer documents that paying early would cause substantial economic harm (čl. 147 st. 2). --- ## Frequently asked questions ### What interest rate applies when a Serbian paušalac pays the monthly tax late? Late-payment interest on tax in Serbia is the National Bank of Serbia reference rate plus 10 percentage points, under ZPPPA article 75. With the reference rate at 5.75% in August 2026, that works out to 15.75% per year. The formula is fixed by statute, but the reference rate moves, so the resulting percentage changes whenever the NBS changes its rate. ### Is the tax late-payment interest in Serbia the same as zatezna kamata? No. Tax interest is the NBS reference rate plus 10 percentage points under ZPPPA article 75, while the civil default interest known as zatezna kamata is the reference rate plus 8 percentage points under a separate law. At a 5.75% reference rate that is 15.75% for tax and 13.75% for civil money debts. Sources that quote 13.75% for unpaid tax are applying the wrong statute. ### When is the monthly paušal tax due in Serbia? The monthly paušal income tax is due within 15 days of the end of the month it covers, under ZPDG article 110 point 1, and the social contributions follow the same deadline under ZDOSO article 60. In practice that means the 15th of the following month, moved forward when the 15th falls on a weekend or a public holiday. The January 2026 obligation, for example, fell due on 18 February 2026. ### Does a Serbian paušalac still owe the monthly tax in a month with no income? Yes. A paušalac has no tax-free allowance: the tax is 10% of the lump-sum income assessed in the rešenje under ZPDG article 38, and the contribution base is that same assessed figure under ZDOSO article 22. Actual turnover in a given month does not change the amount, so a quiet month or a month with no invoices at all does not pause the obligation or the interest clock. ### Is there a fine for paying paušal tax late in Serbia, or only interest? Interest is the automatic consequence and it runs per calendar day from the day after the due date. A monetary fine is a separate matter that comes out of a tax control procedure rather than from the late payment itself: practitioner sources report a range of 10% to 50% of the tax determined in control, with a minimum of 50,000 RSD for an entrepreneur. That figure is cross-checked rather than quoted from the statute. ### What is prinudna naplata and how does it work against a Serbian preduzetnik? Prinudna naplata is the enforced collection of an unpaid tax debt by the Poreska uprava. Serbian practitioner sources describe a consistent sequence: a warning notice giving five days to pay, then a decision on enforced collection, an increase of the debt by 5%, and collection costs of a further 5%. Because an entrepreneur is not a separate legal person, the debt is ultimately answered for with personal assets. ### Can the Poreska uprava block a paušalac's bank account for unpaid tax? A blocked account is an outcome of enforced collection, not the first step. The reported sequence starts with a five-day warning notice and a decision on enforced collection, after which the debt is pursued against the taxpayer's funds and assets. The precise statutory list of collection instruments was not verified for this guide, so treat the account-blocking description as reported practice and check your own position on ePorezi. ### How can a Serbian paušalac check how much tax they owe on ePorezi? Log in to the ePorezi portal with a qualified electronic certificate or an eID account and open the taxpayer card, the stanje na poreskoj kartici. It shows each obligation, the payments booked against it, and any outstanding balance including interest the Poreska uprava has assessed. The card is the authoritative figure; arithmetic you do yourself with the interest formula is only an estimate. ### What is the fine for a paušalac not keeping the KPO knjiga in Serbia? Failing to keep the prescribed business books, or failing to produce them on request, carries a fine of 50,000 to 500,000 RSD for an entrepreneur under ZPPPA article 178b. This is a separate offence from paying tax late, and it runs through the procedural law: the income tax law itself contains no misdemeanour provision for the KPO. Keeping the book current is the cheapest part of the obligation to get right. ### How is late-payment interest on Serbian tax calculated day by day? Interest under ZPPPA article 75 is simple interest, not compounded within the period, calculated per calendar day against a 365-day year, or 366 in a leap year, and it runs from the day after the due date until the day the debt is paid. At an annual rate of 15.75%, a balance of 20,000 RSD outstanding for 30 days produces roughly 259 dinars of interest. The amount the Poreska uprava books on your tax card is the one that counts. --- ## Sources - [Zakon o poreskom postupku i poreskoj administraciji (ZPPPA)](https://www.paragraf.rs/propisi/zakon_o_poreskom_postupku_i_poreskoj_administraciji.html) — čl. 36 (electronic service), čl. 75 st. 1–4 (interest), čl. 142 and čl. 143 (appeal), čl. 147 st. 1–2 (an appeal does not suspend execution), čl. 178b st. 2 (books penalty). - [Zakon o porezu na dohodak građana (ZPDG)](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) — čl. 38 (10% rate, no allowance), čl. 110 t. 1 (payment deadline). - [Narodna banka Srbije — referentna kamatna stopa](https://www.nbs.rs/sr_RS/ciljevi-i-funkcije/monetarna-politika/kamatne-stope/) — the 5.75% reference rate underlying the 15.75% figure. - [Poreska uprava — Preduzetnici paušalci](https://www.purs.gov.rs/preduzetnici-pausalci.html) — the authority's own overview of the regime. - [ePorezi portal](https://eporezi.purs.gov.rs/) — the taxpayer card (*stanje na poreskoj kartici*) and electronic delivery of *rešenja*. # Receiving Foreign Payments in Serbia: Raspored Priliva, Šifre, and Wise Source: https://preduzmi.com/articles/foreign-currency-inflows Published: 2026-06-06, updated 2026-08-21 > How a devizni priliv reaches your account: the raspored deviznog priliva, šifra osnova naplate 302/305/307, the 909 suspense code, EUR invoices to domestic clients, and whether Wise and Payoneer are allowed. *Last updated: August 2026. This guide reflects the [Zakon o deviznom poslovanju](https://www.paragraf.rs/propisi/zakon_o_deviznom_poslovanju.html) ("Sl. glasnik RS", br. 62/2006, 31/2011, 119/2012, 139/2014, 30/2018 i 19/2025) and the [Uputstvo za sprovođenje Odluke o uslovima i načinu obavljanja platnog prometa sa inostranstvom](https://www.nbs.rs/export/sites/NBS_site/documents/propisi/propisi-bop/platni_bilans_uputstvo_platni_promet_p.pdf) ("Sl. glasnik RS", br. 24/2007 … 27/2025).* **In short** - **Your bank does not credit a foreign payment until you allocate it.** It is obliged to credit your account once it has the *podatak o osnovu naplate* from you (Uputstvo t. 7 st. 1) — the *raspored deviznog priliva* — and not before. - **Unallocated money parks on šifra 909** and, if the conditions are never met, goes back to the sending bank under **šifra 109** (Uputstvo t. 9). - **Inflows up to EUR 1,000** on a repeating basis can be covered by a **trajni nalog**, after which the bank credits each one without asking (Uputstvo t. 7 st. 4). - **Šifra osnova naplate:** **302** computer programming, **305** consulting, **307** other services. Your bank's own code list is the authoritative one. - **You may contract with a domestic client in EUR, but payment between residents in Serbia is in dinars** (ZDP čl. 34 st. 1 i st. 10). Invoicing a foreign client in EUR is unaffected. - **Wise, Payoneer and PayPal work for receiving** foreign money you then withdraw to your devizni račun. They are not a channel for domestic payments. ## What the bank actually does when money arrives from abroad **A payment from abroad does not reach your account until you tell the bank what it is for.** **Uputstvo t. 7 st. 1** obliges the bank to credit the beneficiary's account, within the period set by the underlying Odluka, once two conditions are met: the foreign bank has reported that the currency was credited to the Serbian bank's account, **and** the bank has received from you the *podatak o osnovu naplate* — the basis on which you are being paid — together with the data needed to execute the payout. That second condition is the whole point. The money has reached your bank and stays off your account until you supply the basis. The step where you supply that basis is what every Serbian bank calls the **raspored deviznog priliva** — allocating the foreign inflow. The phrase is banking vocabulary, not a statutory term; the obligation behind it is the one in t. 7. What you submit is always the same three things: - **The amount** you are allocating. One inflow can be split across several invoices. - **The invoice number**, which banks often label *kontrolnik* or *broj fakture*. - **The šifra osnova naplate** — a three-digit code describing what the payment is for. Some banks also ask you to attach the invoice or the contract. The Uputstvo requires a document only where one is prescribed as a condition of payout, as t. 8 does for credit transactions through the KZ and KO obrasci. For an ordinary service invoice the attachment is bank practice, applied differently by different banks. Most banks run the step inside e-banking, where the inflow waits in a *neraspoređeni prilivi* queue until you clear it. --- ## Money you never allocate: šifra 909 and šifra 109 **Money you never allocate is booked to the bank's foreign-currency liabilities account under šifra osnova 909, and returned to the bank it came from under šifra osnova 109 if the conditions for payout are never met.** Uputstvo t. 9 prescribes both steps; the bank does not hold the payment informally. | Stage | Instrument | Šifra | What it means | |---|---|---|---| | Inflow arrives, basis not supplied | opšti devizni nalog (slog 66) | **909** | Booked to a foreign-currency liabilities account. Not on your account. | | You allocate it | nalog za naplatu (slog 60) | **302 / 305 / 307 …** | The bank reverses the 909 entry and credits you. | | Conditions are never met | opšti devizni nalog (slog 77) | **109** | Returned in full to the bank it came from. | **The 909 → 109 path ends with your client's money going back to your client.** A returned payment loses a second round of SWIFT fees and restarts the whole collection with your client, so an unallocated inflow is a live problem, not a parked one. --- ## Šifra osnova naplate: 302, 305 and 307 **In everyday practice 302 covers computer programming, 305 covers consulting, and 307 covers other services with no more specific code.** Between them they cover almost every Serbian paušalac in IT and consulting. | Šifra | Typically used for | Common paušal profile | |---|---|---| | **302** | Computer programming, software services | 62.01 Računarsko programiranje, 62.02 | | **305** | Consulting services | 70.22 Business and management consulting | | **307** | Other services with no more specific code | Design, translation, tutoring, other 74.x/85.x | These are the codes Serbian banks and paušal practitioners consistently name for this work, cross-checked across sources rather than read off the codebook here. The codebook is *Prilog 2 — Šifarnik osnova naplate, plaćanja i prenosa u platnom prometu sa inostranstvom*, printed with the NBS Uputstvo as an integral part of it (t. 5), and it does get amended. **In practice, treat the list your bank shows in e-banking as the authoritative one.** It reproduces that codebook, it is what you actually pick from, and the bank keeps it current. Pick the code that describes the work you invoiced: it feeds the National Bank's balance-of-payments statistics, so allocating a service fee under a capital-account basis such as a loan is a misstatement to the bank. The šifra has no effect on your tax, and it never appears in your [KPO knjiga](/articles/kpo-book), which records invoices rather than bank movements. --- ## The EUR 1,000 trajni nalog for recurring clients **For inflows up to EUR 1,000 — or the equivalent in another currency — received on the same basis, you can give the bank a standing instruction and stop allocating each payment by hand.** Uputstvo t. 7 st. 4 says the beneficiary *"može dati banci trajni nalog o osnovu naplate za ove prilive, ako te prilive ostvaruje po istom osnovu"*, and the bank then credits each payment within the normal deadline without asking again. Three conditions travel with it: - **The per-inflow ceiling is EUR 1,000.** It applies to each individual payment, not to a monthly or annual total. - **The basis must be the same every time.** A trajni nalog is for a repeating relationship — the same client, the same kind of service, the same code. - **Anything above the ceiling goes back to manual allocation.** A EUR 2,500 invoice from the same client still needs its own raspored. It is worth setting up if you invoice the same client a small amount every month. Ask your bank how it words the instruction and what its own limits are, because a bank may apply an internal cap below the EUR 1,000 in the Uputstvo. --- ## The "30 days to justify a devizni priliv" rule does not exist **No deadline of 30 days to justify a foreign inflow appears in the Zakon o deviznom poslovanju or in the NBS Uputstvo.** It is repeated constantly in forums and Serbian-language guides, but you cannot point to it in a regulation. What the Uputstvo says is narrower and, in practice, stricter: the bank credits you when it has the basis (t. 7 st. 1), and until then the money sits on 909 and can be returned under 109 (t. 9). The one deadline in the text runs against the bank, not against you. Once it holds the basis it must credit your account within the period set by t. 4 st. 3 of the underlying Odluka. Nothing in either instrument starts a clock on you. **Treat the deadline as your bank's, not the law's.** Because the statute sets no clock, each bank sets its own — the window after which it stops chasing you and starts the return. Ask your bank for its actual policy in writing rather than relying on a number from a forum. Payment and documentation deadlines are always yours to confirm with the institution that will act on them. --- ## Invoicing a domestic client in euros **You may write the contract in EUR, but the payment itself between two Serbian residents is made in dinars.** ZDP čl. 34 st. 1 requires payment, collection and transfer between residents in the Republic to be in dinars. ZDP čl. 34 st. 10 then allows the contract to be denominated in foreign currency — the *valutna klauzula* — while settlement under it stays in dinars. So a domestic invoice can quote "EUR 1,200, payable in RSD at the NBS middle rate on the payment date" and be entirely correct. What it cannot do is ask a Serbian client to send euros. None of this touches the ordinary export case. Invoicing a foreign client in EUR and being paid in EUR to your devizni račun is unaffected by čl. 34. The mandatory fields and the "nije u sistemu PDV" note for those invoices are covered in [invoicing foreign clients](/articles/foreign-invoicing). --- ## Wise, Payoneer and PayPal **They are usable for receiving payments from abroad, which you then withdraw to your Serbian devizni račun. They are not a channel for domestic payments between residents.** | Use case | Wise / Payoneer / PayPal | |---|---| | Foreign client pays you into the platform | Workable | | You withdraw the balance to your devizni račun | Workable — and this transfer is itself a devizni priliv needing a raspored | | A Serbian client pays you through the platform | Not the right channel; čl. 34 st. 1 puts resident-to-resident payment in dinars | | Paying a foreign supplier from the platform balance | Ask your bank and your accountant first | Two consequences follow. **The withdrawal, not the client's payment, is what your bank sees.** It arrives with the platform as the sender, so the invoice number you enter in the raspored is what links it back to your actual client. Where one withdrawal covers several invoices, split the allocation across them. **Platform fees do not reduce your revenue.** Your KPO records the invoiced amount, not the net amount that survived the platform's cut and the bank's conversion. That gap is the usual cause of a bank statement that will not reconcile against the book — see [KPO vs bank statement](/articles/kpo-vs-bank-statement). This inbound-yes, domestic-no reading is the settled practitioner position rather than a line you can quote from one article, so treat an unusual setup — a large balance held abroad, suppliers paid from it — as a question for your accountant. --- ## Which NBS rate, and which date **The type of rate is fixed by law; the date is not.** ZDP čl. 41 st. 2: *"Za potrebe knjigovodstva i statistike primenjuje se zvanični srednji kurs dinara."* Applying the buying rate, the selling rate or the rate your bank used is a *prekršaj*, and for a preduzetnik it carries **150,000 to 500,000 RSD** (ZDP čl. 61 t. 37). The National Bank publishes one list per business day, *"za potrebe knjigovodstva i statistike, kao i za obračun carine i drugih uvoznih dažbina"*. A list is **valid from 08:00 on its date until 08:00 on the day the next list is formed**, and on weekends and public holidays the previous business day's list stays in force. For scale: list no. 157 of 20.8.2026 put **1 EUR at 117.3586 RSD**. **No rule prescribes which date's rate a non-VAT paušalac uses in the KPO.** - **ZPDV čl. 22** fixes the conversion date for the VAT base and binds VAT payers. A paušalac outside the VAT system is not one. - **The Zakon o računovodstvu** defines *preduzetnici* as those keeping double-entry books (čl. 2 t. 3), and a paušalac keeps only the KPO. - **The KPO pravilnik** prescribes no conversion rule and no rate date. **The common practice is to use the middle rate on the invoice date, or on the supply date where the two differ. That is practice, not a prescribed rule.** The Poreska uprava's answer of 29 January 2026 settles which period the entry falls in, not which day's rate converts it. What matters is picking one basis and applying it to every invoice. Whatever date you settle on, the bank's own conversion rate is irrelevant to the book. The difference between the two is a *kursna razlika* — a banking outcome, not revenue. The mechanics of the entry are in the [KPO guide](/articles/kpo-book). --- ## How a foreign inflow counts toward the two limits **Foreign-currency revenue counts in full towards the 6,000,000 RSD paušal limit and generally not towards the 8,000,000 RSD VAT threshold.** | Threshold | Amount | Does EUR revenue from a foreign company count? | |---|---|---| | **Paušal limit** (ZPDG čl. 40 st. 2 t. 4) | **6,000,000 RSD** in the preceding year | **Yes.** Converted to RSD, it counts in full. | | **VAT registration threshold** (ZPDV čl. 33 st. 1) | **8,000,000 RSD** over the previous 12 months | **Generally no** — the supply is performed abroad and drops out of the count. | The VAT side turns on two provisions. ZPDV čl. 33 st. 6 limits *ukupan promet* to the supplies in čl. 28 st. 1 t. 1) and 2) — those taxed in Serbia and those exempt with credit under čl. 24 — and leaves out t. 3), a supply performed abroad. A service to a business client established outside Serbia has its place of supply in the client's country (ZPDV čl. 12 st. 4), so it lands in t. 3). Čl. 12 sets special rules for particular categories of service, so check an unusual one rather than assuming. One detail decides when a foreign invoice lands in the paušal count: **the 6,000,000 RSD limit is measured on invoices issued, not on payments collected.** The Poreska uprava's published answer of 29 January 2026 puts turnover in the period in which the supply was performed and the transaction was documented by an issued invoice and entered in the KPO, regardless of whether and when payment was collected. An invoice issued in December and paid in February belongs to December. So a slow-paying client cannot push revenue into the next year, and the raspored — a banking step — has no effect on which year the revenue falls in. Both thresholds are covered in [revenue limits](/articles/revenue-limits). --- ## Key takeaways 1. **The bank credits a foreign inflow only after it receives the basis of collection from you** (Uputstvo t. 7 st. 1) — the raspored deviznog priliva, which needs the amount, the invoice number and the šifra osnova naplate. 2. **Unallocated funds sit on šifra 909 and go back to the sending bank under šifra 109** if the conditions for payout are never met (Uputstvo t. 9). 3. **Inflows up to EUR 1,000 on the same basis can be covered by a trajni nalog**, after which the bank credits each one without asking (Uputstvo t. 7 st. 4). 4. **302, 305 and 307** are the codes commonly used for programming, consulting and other services — but your bank's published list is the authoritative one. 5. **The widely repeated "30 days to justify an inflow" is not in the law.** No such deadline appears in ZDP or the NBS Uputstvo — the only deadline in the text runs against the bank — so whatever deadline applies to you is your bank's, and it is worth having in writing. 6. **Contracting with a domestic client in EUR is allowed; payment between residents in Serbia is in dinars** (ZDP čl. 34 st. 1 i st. 10). 7. **The rate type is prescribed (zvanični srednji kurs, ZDP čl. 41 st. 2; applying another rate is a prekršaj carrying 150,000 to 500,000 RSD for a preduzetnik under čl. 61 t. 37); the rate date for a non-VAT paušalac is not.** The invoice-or-supply-date convention is practice, so apply it consistently. 8. **Foreign revenue counts in full towards the 6,000,000 RSD paušal limit and generally not towards the 8,000,000 RSD VAT threshold** (ZPDV čl. 33 st. 6, read with čl. 28 st. 1 and čl. 12 st. 4), and the paušal count runs on invoices issued rather than payments collected. --- ## Frequently asked questions ### Does a Serbian paušalac have to complete a raspored deviznog priliva for every payment from abroad? Yes, unless a standing instruction covers it. Under tačka 7 of the NBS Uputstvo, the bank credits the beneficiary's account only once it has received the basis of collection from the beneficiary along with the data needed to execute the payout. Until you supply that, the money is at the bank but not on your account. The only exception is a trajni nalog for repeating inflows up to EUR 1,000. Larger inflows always need their own allocation, even from a client you invoice every month. ### What is šifra osnova naplate 302, 305 and 307 for a Serbian paušalac? They are the three-digit codes describing what a foreign payment is for. In everyday practice 302 is used for computer programming and software services, 305 for consulting, and 307 for other services that have no more specific code. The code affects the National Bank's balance-of-payments statistics, not your tax, and it never appears in your KPO book. Use the code list your own bank shows in e-banking, because it reproduces the National Bank's codebook, it is what you actually pick from, and the codebook does get amended. ### What happens if a paušalac never allocates a devizni priliv? The bank books the amount to a foreign-currency liabilities account under šifra osnova 909, where it is held rather than credited to you. Tačka 9 of the NBS Uputstvo then obliges the bank either to reverse that entry and pay you out once the conditions are met, or to return the same amount to the bank it came from under šifra osnova 109. A returned payment costs another round of transfer fees and restarts the collection with your client. ### Is there really a 30-day deadline to justify a devizni priliv in Serbia? No such deadline was found in the Zakon o deviznom poslovanju or in the NBS Uputstvo, despite how often the figure is repeated. What the rules actually establish is that unallocated funds sit on šifra 909 and can be returned to the sending bank under šifra 109. The only deadline in the text runs against the bank, which must credit you once it holds the basis of collection. Any deadline you are given is your bank's internal policy, so ask your bank for its actual window in writing rather than relying on a forum figure. ### Can a Serbian paušalac set up a trajni nalog for recurring foreign inflows? Yes, for inflows up to EUR 1,000 or the equivalent in another currency, received on the same basis. Tačka 7 stav 4 of the NBS Uputstvo allows the beneficiary to give the bank a standing instruction about the basis of collection, after which the bank credits each individual payment within the normal deadline without separately asking for it. The ceiling applies per inflow, not per month, so a larger invoice from the same client still needs a manual allocation. ### Is Wise legal for a Serbian paušalac to receive payments from foreign clients? Yes, for receiving money from abroad that you then withdraw to your Serbian foreign-currency account. What it is not is a channel for domestic payments, because payment between two residents in Serbia is made in dinars through the domestic system. Note that the withdrawal from Wise to your bank is itself a foreign inflow that needs its own allocation, and that the invoice number you enter should be the one identifying your actual client rather than the platform. ### Can a Serbian paušalac use Payoneer or PayPal to get paid by foreign clients? Yes, on the same terms as Wise: they work for receiving foreign payments that you then withdraw to your devizni račun, and not for domestic payments between residents. Your KPO records the invoiced amount, not the net amount left after platform fees and the bank's conversion, so expect the credited figure to be smaller than the invoice. Keep the platform's transaction records so each withdrawal can be matched back to specific invoices. ### Can a Serbian paušalac issue an invoice in euros to a domestic client? You can denominate the contract and the invoice in euros, but the payment between two Serbian residents is made in dinars. Član 34 stav 1 of the Zakon o deviznom poslovanju puts resident-to-resident payment, collection and transfer in dinars, while stav 10 allows contracting in foreign currency with settlement in dinars — the valutna klauzula. In practice the invoice quotes the euro amount and states that it is payable in dinars at a stated exchange rate. Invoicing a foreign client in euros and being paid in euros is a different case and is unaffected. ### Which NBS exchange rate date does a Serbian paušalac use for a EUR invoice in the KPO book? The type of rate is fixed by law but the date is not. Član 41 stav 2 of the Zakon o deviznom poslovanju requires the official middle rate for bookkeeping and statistics, and breaching that is an offence. No rule prescribes the date for a non-VAT paušalac: the VAT law's conversion rule binds VAT payers, the accounting law covers only entrepreneurs keeping double-entry books, and the KPO pravilnik prescribes no conversion rule at all. Using the middle rate on the invoice or supply date is common practice rather than a prescribed rule, so choose one basis and apply it consistently. ### Does foreign-currency revenue count toward the 6,000,000 RSD paušal limit? Yes. Converted to dinars, revenue from foreign clients counts in full toward the 6,000,000 RSD paušal threshold in član 40 of the Zakon o porezu na dohodak građana. It generally does not count toward the 8,000,000 RSD VAT registration threshold, because that count covers only supplies taxable in Serbia and the place of supply for a service to a foreign business client is the client's country. The count is based on invoices issued and entered in the KPO, not on payments collected, so a late-paying client does not move revenue into the following year. --- ## Sources - [Zakon o deviznom poslovanju](https://www.paragraf.rs/propisi/zakon_o_deviznom_poslovanju.html) — "Sl. glasnik RS", br. 62/2006, 31/2011, 119/2012, 139/2014, 30/2018 i 19/2025 (čl. 34 st. 1 i st. 10; čl. 41 st. 2; čl. 61 t. 37) - [Uputstvo za sprovođenje Odluke o uslovima i načinu obavljanja platnog prometa sa inostranstvom](https://www.nbs.rs/export/sites/NBS_site/documents/propisi/propisi-bop/platni_bilans_uputstvo_platni_promet_p.pdf) — Narodna banka Srbije, "Sl. glasnik RS", br. 24/2007 … 27/2025 (t. 7 i t. 9) - [Zvanični srednji kurs — kursna lista](https://webappcenter.nbs.rs/ExchangeRateWebApp/ExchangeRate/CurrentMiddleRate) — Narodna banka Srbije - Šifarnik osnova naplate, plaćanja i prenosa u platnom prometu sa inostranstvom — Prilog 2 to the Uputstvo above, and an integral part of it (t. 5) - [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon_o_porezu_na_dohodak_gradjana.html) — "Sl. glasnik RS", br. 24/2001 … 6/2026 (čl. 40 st. 2 t. 4) - [Zakon o porezu na dodatu vrednost](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dodatu-vrednost.html) — "Sl. glasnik RS", br. 84/2004 … 109/2025 (čl. 12 st. 4; čl. 22; čl. 28 st. 1; čl. 33 st. 1 i st. 6) - [Poreska uprava's answer of 29 January 2026 on when turnover is recognised](https://www.paragraf.rs/dnevne-vesti/290126/290126-vest11.html) — carried by Paragraf from Biznis i finansije, 27 January 2026 # How to Export an XLS Bank Statement from Alta Banka (Promet po računu) Source: https://preduzmi.com/articles/how-to-export-alta-xls Published: 2026-06-03 > Step-by-step guide for paušalci: export your Alta Banka business account transactions as an Excel (XLS) file you can upload to Preduzmi in under a minute. Preduzmi reads Alta Banka statements directly from the **XLS** (Excel) export of the **Promet po računu** ("Account turnover") report — the same screen you already use to review transactions on your account. No PDF, no screenshots, no manual retyping. Producing the file takes about 30 seconds once you know where to click, and Preduzmi auto-detects the Alta format the moment you upload it. --- ## What you'll need - Active **ALTA eBiz** (web e-banking) access for your Alta Banka business account(s) at [altabanka.rs](https://www.altabanka.rs) - A computer with a browser (the XLS download is a web feature) - The date range you want to import (usually "from start of current month" or "last 3 months") The XLS export lives in **ALTA eBiz**, the web e-banking portal. The **mBiz** mobile app is handy for day-to-day balance checks and may be needed to confirm the web login (2FA push or one-time code) — but the **Promet po računu** export to Excel happens on the desktop. --- ## Step 1 — Log in and open your account Sign in to **ALTA eBiz**. From the home screen (or the **Računi** / Accounts menu on the left), select the account you want to export. For complete accounting and bookkeeping, import **all of your business accounts** — your dinar (RSD) account *and* any foreign-currency (EUR, USD) accounts. Export each account separately; Preduzmi keeps every transaction's original currency. --- ## Step 2 — Open Promet po računu, set the date range, download XLS Open **Promet po računu** (Account turnover) for that account. Then, in order: 1. **Set the date range** in the **Od dana** (From) and **Do dana** (To) fields. Don't worry about overlap — Preduzmi automatically skips any transactions you've already imported, so re-exporting a period you've partly imported is completely safe. You can optionally narrow the results by **Od iznosa / Do iznosa** (amount), **Tip transakcije** (transaction type), or **Opis / Naziv primaoca** (description / payee). 2. **Click the red arrow (►)** to apply the filter and load the matching transactions into the table. 3. **Click the XLS button** in the top-right corner (next to **PDF**). The browser downloads an `.xls` file immediately. The filename is a long string of digits — that's fine, you don't need to rename it. Use **Promet po računu**, not **Pregled izvoda** (statement list). Both can produce files, but Preduzmi parses the *Promet po računu* turnover report — that's the screen with the **Od dana / Do dana** filters and the **PDF / XLS** buttons shown above. **Alta only goes back about 6 months.** The *Promet po računu* export covers roughly the **last 6 months** — Alta won't hand over a longer history. For transactions **older than that**, enter them manually on the Transactions page in Preduzmi; there's no way to export them from Alta. --- ## Step 3 — Upload it to Preduzmi You have two equally fast ways to upload the file: - **From the dashboard** — drag the `.xls` file onto the **Upload bank statement** tile. The dashboard auto-detects the Alta XLS directly, no extra clicks. - **From the Transactions page** — click **Import → Alta (XLS)** and drop the file. Either path goes through the same parser: Preduzmi reads the Alta **Promet po računu** report directly, splits incoming (Uplata) from outgoing (Isplata), and matches payee names automatically. You can re-upload the same period as many times as you want — duplicate transactions are detected by their unique bank entry id ("Vaš broj / Broj naloga") and skipped automatically. --- ## Using the Alta desktop application instead Alta also offers a **desktop e-banking application** (the installed Windows program), and it exports a **different Excel file** than the web ALTA eBiz portal. **Preduzmi reads both** — you upload the desktop app's Excel export exactly the same way, and Preduzmi auto-detects which Alta format it is. If you work in the desktop application: 1. Open the account turnover / transaction list for your account and set the period you want. 2. Use the application's **Export to Excel** option to save the file (it's typically named something like `IzvezeniPodaci.xls`). You don't need to convert it to CSV or open it in Google Sheets first — upload the `.xls` as it is. 3. Upload it to Preduzmi the same way as the web export — drag it onto the **Upload bank statement** tile on the dashboard, or use **Import → Alta (XLS)** on the Transactions page. The desktop export lists each card purchase on its own line (the merchant is in the description), with the amount already signed — minus for outgoing, plus for incoming. Because this format carries **no per-transaction bank id**, Preduzmi de-duplicates it by date + amount + description. Two genuinely identical purchases on the same day (same merchant, same amount) are flagged for your review rather than silently doubled — check the Transactions list if you expect repeats. --- ## Common questions ### Why does Preduzmi accept the XLS export from Alta? Alta's Promet po računu (Account flow) Excel report keeps each value in its own column — date, amount, currency, entry id, payee, account — so parsing is deterministic and Preduzmi reads it directly. PDFs and screenshots are visual documents where OCR errors on amounts or dates cause exactly the kind of bug you can't afford in tax reporting. ### Can I import a PDF or screenshot instead? No — PDFs and screenshots lose or rearrange the fields Preduzmi needs, so stick to the Excel (XLS) export. If you bank elsewhere and only have CSV available, use the Import → Other banks (CSV) option on the same Transactions page, where Preduzmi helps you map your columns. ### What date range should I export from Alta? Export whatever period you haven't imported yet. Preduzmi de-duplicates transactions by their unique bank entry id, so it is safe to export overlapping ranges. A common pattern is to export from the 1st of last month to today, once a month. ### Why are some transactions missing after I upload the XLS? The most common cause is exporting before the list refreshed. If you change the Od / Do dates and immediately click Excel, Alta exports the previously loaded date range, not the new one. Re-open Promet po računu, set the dates, display the results, then export to Excel. Displaying the results means clicking the red arrow (►) after you set the Od dana / Do dana fields, so the table reloads with the new range — only then click XLS. ### How does Preduzmi know the file is from Alta? Preduzmi auto-detects the Alta format from the file content when you upload it — you don't have to label it. It also de-duplicates by the unique entry id (Vaš broj / Broj naloga), so re-importing overlapping periods is safe and never creates double entries. ### Should I import my foreign-currency accounts (EUR, USD) too? Yes. The export screen is identical for every account, and Preduzmi keeps each transaction's original currency, so for complete accounting import every account, not just the dinar one. Export each account separately and upload them all; duplicates across files are still skipped automatically. ### How far back can I export from Alta? About 6 months. Alta's Promet po računu only provides roughly the last half-year of account turnover, so older history can't be pulled through the export. For transactions before that window, enter them manually on the Transactions page in Preduzmi — Alta has no way to export them. ### Can I use the export from the Alta desktop application? Yes. The Alta desktop (Windows) e-banking application exports a different Excel file than the web ALTA eBiz portal, and Preduzmi reads both — just upload the desktop app's Excel (.xls) export the same way; the format is auto-detected. The desktop export has no per-transaction bank id, so Preduzmi de-duplicates it by date, amount and description; two identical purchases on the same day are flagged for review rather than doubled. --- ## Where to learn more Alta Banka's own ALTA eBiz / mBiz user guide covers the **Promet po računu** screen, including the same Excel export option: [Alta Banka — altabanka.rs](https://www.altabanka.rs) If the export screen doesn't look like the screenshots above, Alta has likely updated the UI — the official help page is the source of truth. # How to Export an XML Bank Statement from Raiffeisen (Moja eBanka biznis) Source: https://preduzmi.com/articles/how-to-export-raiffeisen-xml Published: 2026-05-25 > Step-by-step guide for paušalci: export your Raiffeisen business account transactions as an XML file you can upload to Preduzmi in under a minute. Preduzmi reads Raiffeisen bank statements directly — but only in **XML** format. PDFs and screenshots won't work, and the TXT/XLS exports lack the structured fields we need. The good news: getting the XML takes about 30 seconds once you know where to click. This guide walks through it with screenshots, for both the web bank and the mobile app. --- ## What you'll need - Active **Moja eBanka biznis** access for your Raiffeisen business (dinar) account - A computer with a browser (this is a web-only flow) - The date range you want to import (usually "from start of current month" or "last 3 months") The XML export is available only in the **web banking** at [rol.raiffeisenbank.rs](https://rol.raiffeisenbank.rs). The Raiffeisen mobile app is still useful — you may need it to confirm the web login (2FA push or one-time code) — but the XML download itself happens on the desktop. --- ## Step 1 — Log in and open your dinar account Sign in to [Moja eBanka biznis](https://rol.raiffeisenbank.rs). On the **Računi** (Accounts) screen, click your **Dinarski račun** (dinar account). Foreign-currency accounts (USD, EUR) use the same form, but for paušal tax reporting you only need the dinar account. --- ## Step 2 — Set a date range, refresh, then download XML You'll land on the **Promet i transakcije** (Transactions) view for that account. Three things to do, in order: 1. **Set the date range** in the **Od** (From) and **Do** (To) fields. The default range only covers the last few days — widen it to cover the period you want to import. 2. **Click the refresh button** (the yellow circular arrow on the right). This is the easy step to miss — without it the export uses the *previous* filter, not your new dates. 3. **Click XML** in the row of export buttons (next to PDF / TXT / XLS). The browser downloads a `.xml` file immediately. The filename is a long string of digits — that's fine, you don't need to rename it. **Don't skip the refresh step.** If you change the dates and immediately click XML, Raiffeisen exports the *previously loaded* date range. The download succeeds silently — so the mistake is only visible later when transactions are missing in Preduzmi. --- ## Step 3 — Upload it to Preduzmi You have two equally fast ways to upload the file: - **From the dashboard** — drag the `.xml` file onto the **Upload bank statement** tile. The dashboard accepts XML directly, no extra clicks. - **From the Transactions page** — click **Upload Raif. XML** and drop the file. Either path takes you through the same parser: Preduzmi reads every transaction, splits incoming from outgoing, and matches payee names automatically. You can re-upload the same period as many times as you want — duplicate transactions are detected by their unique bank reference and skipped automatically. --- ## Common questions ### Why does Preduzmi only accept the XML export from Raiffeisen? XML is a structured format with one canonical field per value (date, amount, currency, reference, payee), so parsing is deterministic. PDF, TXT, and XLS exports are formatted for human reading and lose or rearrange fields that Preduzmi needs to reconcile transactions accurately. PDFs are the worst case: the same bank statement can be laid out a hundred different ways, and OCR errors on amounts or dates cause exactly the kind of bug you can't afford in tax reporting. ### Can I import a TXT or XLS export instead? Not the Raiffeisen TXT or XLS exports — they are formatted for human reading and skip fields Preduzmi needs. If you bank elsewhere and only have CSV available, use the Upload CSV option on the same Transactions page, where Preduzmi helps you map your columns. ### What date range should I export from Raiffeisen? Export whatever period you haven't imported yet. Preduzmi de-duplicates transactions by their unique bank reference, so it is safe to export overlapping ranges. A common pattern is to export from the 1st of last month to today, once a month. ### Why are some transactions missing after I upload the XML? The most common cause is skipping the refresh step in Moja eBanka biznis. If you change the Od / Do dates and immediately click XML, Raiffeisen exports the previously loaded date range, not the new one. Re-open the Promet i transakcije view, set the dates, click the yellow refresh button, then click XML. The download succeeds silently, so the mistake is only visible later, when transactions are missing in Preduzmi. ### Can I export XML from the Raiffeisen mobile app instead of the web? No — the XML export is a web-banking feature. The Raiffeisen mobile app shows transactions but does not produce the structured XML statement Preduzmi needs. You may still need the mobile app to approve the web login (2FA push or one-time code), but the download itself happens on the desktop at rol.raiffeisenbank.rs. ### Do I need to export transactions from my foreign-currency (EUR, USD) account? Not for paušal tax reporting. Your KPO obligations are based on dinar account activity — that is where client payments and tax-relevant outflows live. Foreign-currency accounts can be imported too but are optional. The export form is identical for them. --- ## Where to learn more Raiffeisen's own help center has a short overview of the **Pregled računa** screen, including the same XML export button: [Pregled računa na Moja eBanka biznis — Raiffeisen Knowledge Base](https://help.raiffeisenbank.rs/knowledge-base/pregled-racuna-na-moja-ebanka-biznis/) If the export form doesn't look like the screenshots above, Raiffeisen has likely updated the UI — the official help page is the source of truth. # Eko Taksa for Paušalci: Serbia's Annual Environmental Fee, Explained Source: https://preduzmi.com/articles/eko-taksa Published: 2026-05-21, updated 2026-08-21 > How much eko taksa costs, when to file Obrazac 1, where to pay, and what new paušalci need to know about Serbia's annual local environmental fee. *Last updated: August 2026. Reflects the* Zakon o naknadama za korišćenje javnih dobara *and the* Uredba o kriterijumima za određivanje aktivnosti koje utiču na životnu sredinu i iznosima naknada *("Sl. glasnik RS", br. 30/2024).* **The short version** - **What it is:** A small annual local fee that almost every paušalac pays, called *naknada za zaštitu i unapređivanje životne sredine* — eko taksa for short. Local, not republic-level. - **How much:** For most service-based paušalci (IT, consulting, design, photography, education), **5,000 RSD per year** — about €43. Activities with a bigger environmental footprint pay 10,000 or 20,000 RSD. - **What you file:** A one-page form called **Obrazac 1**, once a year. - **Filing deadline:** **April 30** each year. - **When you pay:** Four quarterly installments, by the 15th of the month after each quarter ends — or pay the full annual amount in one go. - **If you're new:** File Obrazac 1 within 15 days of registering your business (čl. 138 st. 3). The calendar year in which you register is exempt by statute (čl. 137 st. 2), but the filing is still required. ## What is eko taksa, exactly? The eko taksa is a local environmental fee paid by businesses in Serbia, calculated by how much their activity is considered to affect the environment. It funds local environmental programs run by the city or municipality (*opština*) where your business is registered. A few things make it different from your regular monthly paušal obligations: - **It's local, not republic-level.** Your monthly *porez* and *doprinosi* go to Poreska uprava. Eko taksa goes to your **lokalna poreska administracija (LPA)** — in Belgrade, that's the *Sekretarijat za javne prihode Grada Beograda*; elsewhere it's the LPA of your *opština*. - **It's annual, not monthly.** One filing, one annual amount, paid in quarterly chunks (or all at once if you prefer). - **The bracket is set by your activity, not your revenue.** Revenue enters only as a ceiling: the fee cannot exceed 0.4% of the previous year's total (čl. 137), which for most paušalci is far above the bracket amount. The legal basis: the eko taksa is regulated by the *Zakon o naknadama za korišćenje javnih dobara* ("Sl. glasnik RS", br. 95/2018 with amendments), and specifically by the *Uredba o kriterijumima za određivanje aktivnosti koje utiču na životnu sredinu i iznosima naknada* ("Sl. glasnik RS", br. 30/2024), which sets out which activities pay what. ## Who has to pay it (and who doesn't) The short answer: **most paušalci do**. The slightly longer answer: it applies to all legal entities and entrepreneurs whose *registered primary activity* (*pretežna delatnost*, the one you chose when you registered with APR) appears in the list attached to the Uredba. Almost every common paušalac activity is on that list. Some activities aren't listed — meaning, technically, no fee is owed. But here's the catch: **most LPAs still expect you to file Obrazac 1 anyway**. They'll then issue a decision (*rešenje*) confirming you owe nothing. Skipping the filing because you think you don't owe anything can backfire — if an LPA later disagrees with your interpretation, they can charge you retroactively and impose a fine for not filing. **Rule of thumb** If you're a paušalac, file Obrazac 1. If your activity isn't on the list, the LPA will issue a zero-obligation *rešenje*, and you've done your part. ## How much you'll pay For paušalci (treated as *mikro preduzetnici* under the Uredba), the annual amounts depend on the environmental impact category of your activity: | Impact category | Annual amount (RSD) | Roughly in EUR | |---|---|---| | Mali (low) | **5,000** | ~€43 | | Srednji (medium) | **10,000** | ~€85 | | Veliki (high) | **20,000** | ~€170 | For typical service-based paušalci, you're almost certainly in the **mali** (low impact) bracket. That covers: - **62.01** — Računarsko programiranje (computer programming) - **62.02** — Konsultantske delatnosti u IT - **70.22** — Business and management consulting - **74.10** — Specialized design activities - **74.20** — Photography services - **85.59** — Other education (language schools, courses, training) If you do something more industrial — printing prep work (18.13), waste collection (38.11), brewing (11.05) — you may land in the medium or high category. Your *šifra delatnosti* (the activity code from your APR registration) determines which. There's also a cap built into the Uredba: the fee can't exceed **0.4% of your total revenue from the previous year**. For a paušalac, "total revenue" here is the *paušalno utvrđen prihod* from the previous year's *rešenje* — the assessed amount you are taxed on, not what actually landed in the bank account. For a paušalac with low to moderate revenue this cap is almost never triggered, but it's there. ## The annual filing: Obrazac 1 Once a year, you file a one-page form called **Obrazac 1** with your LPA. This form tells them who you are, what you do, and which impact category applies. The form is prescribed by the *Pravilnik o izgledu, sadržini i načinu dostavljanja prijave* ("Sl. glasnik RS", br. 30/2024). The deadline is **April 30 of the current year, for the current year**. (This used to be July 31, but it was moved to April 30 starting in 2024.) A common question: *do I need to file every year, even if nothing's changed?* Legally, the obligation to file kicks in when something changes — your address, your activity code, your impact category, opening or closing the business. If nothing changes, you could in theory skip filing. **In practice, most LPAs prefer you file annually** as a way of confirming "yes, my situation is still the same." Filing every April 30 is the safe default, takes a few minutes, and avoids confusion later. ## When and how to pay After you file Obrazac 1, your LPA issues a *rešenje* — a decision that includes your annual amount, the account number to pay into, and the unique *poziv na broj* (reference number) you'll use for every payment. Payments work like this: - The annual amount is split into **four equal quarterly installments**. - Each installment is due within **15 days after the end of the quarter** — so the deadlines are **April 15, July 15, October 15, and January 15** of the following year. - The account number is always **840-714562843-56** (this is a national account, the same everywhere in Serbia). - The *šifra plaćanja* is **253** if you're paying from your business bank account. - The *poziv na broj* comes from your *rešenje* and is unique to you — it includes a code for your *opština* and your PIB. The *rešenje* itself usually arrives in your electronic mailbox on the JIS LPA portal a few weeks to a few months after you file. Until it arrives, you technically don't have a *poziv na broj* to use — so the first quarterly installment is often paid a bit late, without penalty, simply because the *rešenje* hadn't arrived yet. **One *rešenje*, many years** Unlike Poreska uprava, which can issue a fresh *rešenje* each year for your monthly obligations, an LPA typically issues one *rešenje* and reuses the same *poziv na broj* in subsequent years. Don't expect a new one to arrive every January — your existing reference number stays valid. ## Can you pay for the whole year at once? **Yes — and for many paušalci, this is the simplest option.** The law sets out quarterly installments as the schedule, but it doesn't forbid prepayment. The Treasury (*Uprava za trezor*) accepts the full annual amount as a single transfer with no issue. The LPA's system simply applies the prepayment against each quarterly obligation as it comes due. For a low-impact paušalac paying 5,000 RSD a year, splitting that into four payments of 1,250 RSD is more administrative work than it's worth. A single annual payment in March or April (once you have your *rešenje* and *poziv na broj*) gets it out of the way for the year. A small caveat: some LPAs send *opomene* (payment reminders) automatically based on the quarterly calendar, without checking your actual payment status first. If you've prepaid the whole year and still get a reminder for the second quarter, you can either ignore it (if you're confident in your prepayment) or check your balance on the JIS LPA portal to confirm. Neither costs you anything. ## How to file: your options You can file Obrazac 1 in several ways. The routes available: - **Online, through the JIS LPA portal** (`lpa.gov.rs`). Usually the fastest option and available in every *opština*. You'll need a *kvalifikovani elektronski sertifikat* (a qualified electronic signature, available for free on your biometric Serbian ID card via MUP, or on a smart card from Pošta Srbije or Halcom) or an **eID** account. - **In person, at the pisarnica of your LPA**. In Belgrade, that's the relevant *odeljenje* of the Sekretarijat za javne prihode covering your *opština sedišta* (Savski Venac, Stari Grad, Novi Beograd, and so on). Elsewhere, it's the LPA of your *opština*. - **By registered mail** to your LPA's address. - **By email**, in some Belgrade *opštine*, which accept scanned forms sent to dedicated email addresses. This varies — check what your specific *opština* accepts. Whichever route you choose, the form itself is the same one-pager. If you're using software that generates a pre-filled Obrazac 1 from your business profile, you can typically print or download it and submit it through any of the above channels. ## If you're a new paušalac Two things to know. **First, the first-year filing.** When you register your paušalac status with APR, you're expected to file Obrazac 1 with your LPA **within 15 days of registration**. This is on top of the regular April 30 deadline — so if you register in, say, October, you don't wait until April; you file within 15 days. The relevant rule is *čl. 138 st. 3* of the *Zakon o naknadama za korišćenje javnih dobara*. **Second, the first-year amount.** The calendar year in which the business is founded or registered is exempt by statute: *Zakon o naknadama za korišćenje javnih dobara* **čl. 137 st. 2** takes that year out of the obligation outright, independent of any revenue calculation. So the amount for the year you register is **zero** — not because a formula produced zero, but because the year itself is excluded. The filing still stands: you submit Obrazac 1, the LPA issues a *rešenje* showing 0 RSD or no payment due, and that's it. From the second year onward, you're a normal paying paušalac, with a regular April 30 filing and quarterly payments. **Heads up for first-year founders** A few new paušalci skip the first-year filing because there's nothing to pay. This is a mistake. The filing creates a record of you in the LPA's system. Skipping it can lead to a *prekršajna kazna* (administrative fine) later, even though no actual fee was owed. ## If something changes mid-year If anything significant about your business changes during the year — you move your *sedište* to a different *opština*, you change your *šifra delatnosti* to one in a different impact category, you pause the business (*mirovanje*) or close it entirely — you need to file an updated Obrazac 1 within **15 days of the change**. A few specifics: - **Moving to a different *opština*.** You'll need to deregister with the old LPA and register with the new one. APR's address change automatically notifies tax authorities, but the local fee filing is a separate step you handle yourself. - **Mirovanje (temporary suspension).** During *mirovanje*, you don't pay eko taksa for the period you're paused. When you resume, file an updated Obrazac 1 within 15 days, and the LPA will calculate the prorated amount for the rest of the year. - **Closing the business.** Before you can deregister with APR, the LPA will require confirmation that all local fees are paid up — including any back-dated eko taksa they think you owe. Skipping filings in earlier years can create a real headache here, because the LPA can retroactively assess the fees and you'll need to clear them before closing. ## What happens if you don't file Filing Obrazac 1 is a legal obligation. Not filing is a *prekršaj* (administrative offense) under the *Zakon o naknadama za korišćenje javnih dobara*, with fines ranging from **5,000 to 150,000 RSD** for an entrepreneur. The fee itself, if owed, also accrues *zatezna kamata* (default interest) under the *Zakon o poreskom postupku i poreskoj administraciji* until it's paid. In practice, LPAs don't aggressively chase missed filings every year. The bigger risk is that the missed filing surfaces later — when you try to close your business, change your *sedište*, or apply for something that requires proof of clean local-tax status. At that point, the LPA can assess the missed years all at once and add interest, which is far more painful than just filing on time. The takeaway: the eko taksa filing is small, cheap, and low-effort. The downside of missing it is asymmetric — small fee, but potentially big and very inconvenient consequences if it catches up with you. ## Don't confuse eko taksa with other "green" fees There are a few other Serbian fees with "environmental" in the name, and they sometimes get mixed up. Here's what eko taksa is **not**: - **Naknada za ambalažu** — a fee on packaging, paid by producers and importers of products that come in packaging. If you're a service-based paušalac (IT, consulting, design, etc.), this doesn't apply to you. - **Eko taksa for vehicles** — paid when you register a car, motorcycle, or other vehicle with MUP. Unrelated to your business activity. - **Naknada za posebne tokove otpada** — a fee on producers of products that become specific waste streams (electronics, tires, oils, etc.). Also a producer obligation, not relevant to most service paušalci. If someone tells you that you owe one of these because you're a paušalac, double-check — usually it's a misunderstanding. ## Quick recap - **Eko taksa is a local annual fee**, handled by your LPA, not Poreska uprava. - **Most service-based paušalci pay 5,000 RSD per year.** - **File Obrazac 1 by April 30 each year**, plus within 15 days when you first register or when something changes. - **Pay in four quarterly installments, or just pay the full annual amount in one go** — both are fine. - **First year: you file, but you don't pay** — the year of founding or registration is exempt under čl. 137 st. 2. - **Don't skip the filing**, even if you think you don't owe anything. The downside of a missed filing is much bigger than the few minutes it takes to do it right. ## Frequently asked questions ### How much is the eko taksa for paušalci in Serbia? For most service-based paušalci (IT, consulting, design, photography, education), the eko taksa is **5,000 RSD per year** — roughly €43. Activities classified as medium environmental impact pay 10,000 RSD; high-impact activities pay 20,000 RSD. The fee is capped at 0.4% of the previous year's total revenue — for a paušalac, the *paušalno utvrđen prihod* from that year's *rešenje*. ### What is Obrazac 1? Obrazac 1 is a one-page form filed annually with your local tax administration (LPA). It declares your business, activity code, and the environmental impact category that applies, and it's the basis on which the LPA issues a *rešenje* with your annual eko taksa obligation. ### When is the eko taksa deadline in Serbia? The Obrazac 1 filing deadline is **April 30 each year**. The annual amount is split into four quarterly installments due by **April 15, July 15, October 15, and January 15** of the following year — though you can also prepay the full annual amount in a single transfer. ### Do new paušalci pay eko taksa in their first year? No — the calendar year in which the business is founded or registered is exempt under *Zakon o naknadama za korišćenje javnih dobara* čl. 137 st. 2, whatever the revenue in it turns out to be. **But you still have to file Obrazac 1 within 15 days of registering your paušalac status with APR (čl. 138 st. 3).** Skipping that filing can lead to an administrative fine later, even though no actual money was owed. ### Can I pay the eko taksa for the whole year at once? Yes. While the law schedules four quarterly installments, the Treasury accepts a single annual transfer, and the LPA's system applies it across the quarters automatically. For a 5,000 RSD/year paušalac, a single payment in March or April (once your *rešenje* arrives) is the simplest option. ### Where do I file Obrazac 1? With your local tax administration (LPA). In Belgrade, that's the *Sekretarijat za javne prihode Grada Beograda*; elsewhere, it's the LPA of your *opština*. You can file online through the JIS LPA portal (lpa.gov.rs), in person at the *pisarnica*, by registered mail, or — in some Belgrade *opštine* — by email. ### What happens if I don't file Obrazac 1? Not filing is an administrative offense (*prekršaj*) with fines from **5,000 to 150,000 RSD** for an entrepreneur. The unpaid fee also accrues default interest. Practically, LPAs don't chase every missed filing immediately, but missed years catch up when you try to close the business, change your address, or apply for anything that needs a clean local-tax certificate. ### Is eko taksa the same as VAT or income tax? No. **Eko taksa is a local environmental fee** handled by your municipal LPA. **VAT (PDV)** is a republic-level consumption tax — and paušalci aren't in the VAT system at all unless their revenue crosses the threshold. **Income tax (*porez na prihode*)** and social contributions are paid monthly to Poreska uprava based on your *rešenje*. The three obligations are completely separate. ### Does the eko taksa apply to paušalci with zero or low revenue? The filing applies; the fee depends on the previous year's revenue — for a paušalac, the *paušalno utvrđen prihod* from that year's *rešenje*. The Uredba caps the fee at 0.4% of it, which means a paušalac with a very low assessed base may owe less than the standard 5,000 RSD bracket amount — though for most paušalci this cap doesn't kick in. Either way, Obrazac 1 must still be filed. # Agency vs Paušalac: The IT Freelancer's Decision Guide Source: https://preduzmi.com/articles/agency-vs-pausalac Published: 2026-03-18, updated 2026-08-21 > Compare working through a Serbian agency versus running your own paušalac. Real numbers, independence test analysis, and a full side-by-side comparison to help you choose. *Last updated: August 2026. Tax rates and contribution amounts reflect current legislation under the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, consolidated through br. 6/2026).* If you're an IT professional in Serbia working for a foreign client, you've almost certainly encountered this fork in the road: register your own paušalac and handle everything yourself, or work through a Serbian agency (sometimes called an "umbrella company" or "employer of record") that employs you formally and handles all tax and compliance on your behalf. Both models are legal. Both are widely used. And the decision between them involves tradeoffs that go well beyond the tax rate — including independence test risk, social benefits, administrative burden, and how much of your gross income you actually take home. This guide compares both options with real numbers, not generalizations. --- ## How each model works ### The agency model You sign an employment contract (ugovor o radu) with a Serbian agency. The agency signs a service agreement with your foreign client. Money flows: client → agency → you (as salary). The agency handles: - Your employment registration (Obrazac M, CROSO) - Monthly salary calculation and tax withholding - All social contributions (employer and employee portions) - Tax filing and payment - Health insurance booklet maintenance - Compliance with Serbian labor law You receive a net salary. The agency takes a commission (typically 3–10% of the gross amount from the client, or a fixed monthly fee of €100–300). ### The paušalac model You register your own preduzetnik at APR, choose paušalno oporezivanje, sign a service agreement directly with your foreign client, issue invoices, receive payments to your business bank account, and handle all tax obligations yourself (four monthly payments, KPO knjiga, limit tracking). You keep everything the client pays minus your tax obligations and business costs. There is no intermediary. --- ## What each model charges, and on what base The two models differ less in their rates than in what those rates apply to. In the agency model every deduction is a percentage of the money flowing from the client. In the paušal model the tax and contributions are fixed in advance by your *rešenje* and do not move when your revenue does. ### Agency: proportional to what the client pays | Charge | Rate | Base | Who bears it | |--------|------|------|--------------| | Agency commission | 3–10%, or a flat €100–300/month | The gross the client pays (some agencies charge on your salary instead) | Deducted before your salary is set | | Employer contributions | ~16.15% — PIO 10%, health 5.15%, unemployment 0.75%, injury 0.25% | Bruto 1 | The employer, out of the total employment cost (bruto 2) | | Income tax | 10% | Salary above the non-taxable amount (~19,300 RSD/month) | You, withheld from salary | | Employee PIO | 14% | Bruto 1 | You, withheld | | Employee health | 5.15% | Bruto 1 | You, withheld | | Employee unemployment | 0.75% | Bruto 1 | You, withheld | Every line scales with the amount: if the client's rate doubles, each deduction doubles with it. In return the agency carries the entire administrative and labour-law side — payroll, filings, sick pay, paid leave, severance — and none of it reaches you. ### Paušalac: fixed by the rešenje | Charge | Amount | Base | Who bears it | |--------|--------|------|--------------| | Monthly income tax | ~4,500 RSD | *Paušalno utvrđen prihod* from your rešenje — not what the client pays | You | | Monthly PIO | ~10,800 RSD | The same assessed base | You | | Monthly health insurance | ~4,635 RSD | The same assessed base | You | | Monthly unemployment | ~338 RSD | The same assessed base | You | | Bank costs | ~€10 per inbound transfer (SWIFT + conversion) | Each payment received | You | For a typical IT paušalac the four tax lines come to roughly 20,273 RSD a month, and they stay there whether the client pays €1,000 or €4,000: they are computed on the assessed base, not on your revenue. What moves in the other direction is everything the agency was absorbing — KPO knjiga, four monthly payments, limit tracking, bank reconciliation, and unpaid time whenever you are ill or on holiday. Two ceilings also bound the arrangement: 6,000,000 RSD of revenue in a calendar year (paušal status) and 8,000,000 RSD in any rolling 12 months (PDV). Neither column is a prediction for you. The agency figures depend on its fee structure and on whether it charges on the gross from the client or on your salary; the paušal figures come from your own *rešenje*, which varies by activity code, municipality, and years of registered experience. Take the structure from the tables and put your own numbers into it. ### Reading the two columns One arrangement takes a proportion of everything you bill; the other takes a fixed monthly amount that ignores what you bill. Which of them produces the larger charge at your revenue level depends on your rešenje, your municipality, the agency's commission, and how much you actually invoice. And the charge is only half of the comparison, because the agency's price covers obligations — sick pay, paid leave, severance, all the filing — that a paušalac funds personally or does without. --- ## The comparison doesn't end at the monthly charge The charge structure is one input among several. The agency model persists because it carries protections that neither table above prices. ### Full comparison table | Factor | Agency (employment) | Paušalac | Winner | |--------|-------------------|----------|--------| | **How the charge is set** | Proportional — every deduction scales with what the client pays | Fixed — tax and contributions set by the rešenje, independent of revenue | Depends on your revenue | | **Independence test risk** | Zero — you're an employee | Significant, especially with one client | Agency | | **Administrative burden** | None — agency handles everything | KPO, 4 monthly payments, limit tracking, bank reconciliation | Agency | | **Health insurance** | Automatically active, employer maintains | Must verify yourself, occasional RFZO issues | Agency | | **Sick leave (first 30 days)** | Paid by employer (at 65%+ of salary) | Self-funded, zero compensation | Agency | | **Paid vacation** | Legally mandated 20+ days | No concept of paid time off | Agency | | **Paid public holidays** | Legally mandated | Not compensated | Agency | | **Maternity leave** | Full protection under labor law | Available but more complex process | Agency | | **Pension accrual** | Based on actual salary (higher base) | Based on assessed paušal base (lower) | Agency | | **Severance if terminated** | Required by law | Nothing | Agency | | **Revenue limits** | Not applicable | 6M (paušal) + 8M (PDV) must be tracked | Agency | | **Flexibility to take other clients** | May be restricted by employment contract | Full freedom (subject to independence test) | Paušalac | | **Control over invoicing and payments** | None — agency handles | Full control, direct client relationship | Paušalac | | **Business deductions** | Cannot deduct personal expenses | Cannot deduct either (paušal), but no taxable expenses | Tie | | **Long-term career building** | Building employment history | Building business/client portfolio | Depends on goals | | **Accountant needed** | No | No (but recommended) | Tie | | **Speed to start** | 1–2 weeks (agency onboarding) | 1–2 weeks (APR registration + rešenje) | Tie | --- ## The independence test: the elephant in the room The independence test (test samostalnosti) is the single biggest risk factor for paušalci working with a single foreign client. If you fail 5 of 9 criteria, income from that client is reclassified as *drugi prihodi* and leaves the fixed paušal charge entirely: 20% tax on the **gross** amount (ZPDG čl. 86 st. 1, with no normirani troškovi — čl. 85 st. 5 t. 1 carves point 17 out of the general deduction) plus 24% PIO on the same base (ZDOSO čl. 44 st. 1 t. 1, čl. 28 st. 1), withheld at source where the payer is a Serbian *nalogodavac* (ZPDG čl. 85 st. 15–17). Retroactive assessment for prior periods is possible on top. The typical IT freelancer working full-time for one foreign client is borderline on the independence test. As detailed in our [independence test guide](/articles/independence-test), common failure points include: revenue concentration > 70% from one client, client-set schedules, open-ended engagements, and pure time-and-materials billing. **Failing the independence test moves that client's income out of the paušal arrangement altogether.** It is then charged on the gross the client pays rather than on your assessed base: 20% tax (ZPDG čl. 86 st. 1) and 24% PIO (ZDOSO čl. 44 st. 1 t. 1) — 44% of gross on those two components alone. The 10.3% health contribution arises only for someone not already health-insured on another basis, which a registered paušalac is. Retroactive assessment for prior periods is possible on top. **Risk assessment by scenario:** | Situation | Independence test risk | Recommendation | |-----------|----------------------|----------------| | Single foreign client, full-time, 2+ years | **High** — likely fails 5+ criteria | Consider agency OR restructure contract + add clients | | Primary client (70%) + 1–2 smaller clients | **Moderate** — may pass if contract is well-structured | Paušalac with proper contracts | | 3+ clients, none exceeding 50% | **Low** — easily passes criterion 1 | Paušalac is clearly better | | Short-term project (< 6 months) | **Low** — doesn't trigger permanence criterion | Paušalac | If your situation is high-risk and you can't diversify clients or restructure your contract, the agency model eliminates this risk entirely. You're an employee — the independence test doesn't apply to employment relationships. --- ## The hybrid approach Some freelancers use a hybrid strategy: they're employed through an agency for their primary client (eliminating the independence test risk for that relationship) and run a paušalac on the side for smaller projects and additional clients. This is legal, provided: - You declare the dopunska delatnost (side business activity) properly - As a side-business paušalac, you pay only income tax (10%) and PIO (24%) — not health and unemployment (those are covered by your employment) - Your paušal revenue stays under the 6M limit The hybrid approach gives you the security of employment (health insurance, paid leave, no independence test) for your main income, while the additional earnings are charged under the paušal rules — a fixed monthly amount set by the rešenje rather than a proportion of what you invoice. --- ## When to choose the agency model The agency model makes sense when: 1. **You have a single long-term client and can't diversify.** The independence test risk is real, and employment removes it: the test does not apply to an employment relationship at all. 2. **You value social protections.** Paid sick leave from day 1, paid vacation, maternity protections, higher pension accrual — these have real monetary value that the net income comparison doesn't capture. If you plan to take significant time off, get sick, or start a family, the agency model provides a safety net that paušal doesn't. 3. **You don't want to deal with compliance.** No KPO, no limit tracking, no monthly payment juggling, no ePorezi, no rešenje management. Some people genuinely value having zero administrative overhead. 4. **Your client requires it.** Some foreign companies refuse to contract directly with individual preduzetnici due to their own compliance requirements (permanent establishment risk, co-employment concerns). They'll only work through a local employment entity. 5. **You're new to Serbia and overwhelmed.** The agency model lets you start earning immediately while you learn the system. You can always register a paušalac later when you're comfortable. --- ## When to choose the paušalac model The paušalac model makes sense when: 1. **You have multiple clients** or can structure your work to pass the independence test. Diversification is what keeps the arrangement stable: a single-client engagement is the one that gets tested, and reclassification takes that client's income out of the fixed paušal charge. 2. **You're comfortable with basic financial administration.** The actual work is minimal (30 minutes/month with proper tools), but you need to be responsible about it. 3. **You value autonomy and direct client relationships.** As a paušalac, you negotiate your own rates, control your schedule, and build your own business reputation. 4. **You have an emergency fund.** Without employer-provided sick leave and paid vacation, you need personal savings to cover non-working periods. 5. **Your revenue is well within limits** and you don't anticipate exceeding 6M RSD in a calendar year. --- ## The question most people don't ask: what about pension? This deserves special attention because the long-term impact is significant and usually ignored in short-term income comparisons. Pension points are calculated from the base your PIO contributions are paid on, and the two models use different bases. A paušalac pays PIO on the assessed *paušalno utvrđen prihod* — commonly around 45,000 RSD/month — whatever the client pays. An agency employee pays PIO on bruto 1, the actual gross salary, which for a €4,000/month engagement lands near 375,000 RSD/month. Over a 20-year career: - The paušalac accumulates points earned on ~45,000 RSD/month - The agency employee accumulates points earned on the full salary base The resulting pension difference is substantial. Many paušalci plan to compensate through private pension savings (dobrovoljno penzijsko osiguranje) or investment, but few actually do the math or set up the contributions. --- ## Key takeaways 1. **The two models are charged on different bases.** The agency deducts a percentage of everything the client pays; the paušalac pays a fixed monthly amount set by the rešenje, regardless of revenue. Put your own rešenje and your own agency quote into that structure before deciding. 2. **The independence test is the paušalac's biggest risk.** Single-client, long-term arrangements are vulnerable. Reclassification moves that client's income out of the fixed paušal charge and onto the gross the client pays. 3. **Social protections have monetary value.** Paid sick leave, vacation, higher pension accrual — these matter over a career, and they are exactly what a comparison of monthly charges leaves out. Twenty days of unpaid vacation and a lower lifetime pension base are real costs on the paušal side. 4. **The agency model offers simplicity and security.** Zero compliance burden, zero independence test risk, full labor law protections. 5. **The hybrid approach works well** for freelancers with a primary client plus side projects. 6. **Your specific situation determines the right choice.** Number of clients, risk tolerance, life stage, and administrative comfort all factor in. There's no universally correct answer. # Paušalac vs Knjigaš: Which Serbian Tax Regime Is Right for You? Source: https://preduzmi.com/articles/pausalac-vs-knjigash Published: 2026-03-18 > Compare paušalno oporezivanje (lump-sum taxation) with full bookkeeping for Serbian entrepreneurs. Tax calculations, break-even analysis, and a practical guide to choosing the right regime. *Last updated: March 2026. Reflects current legislation under the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, consolidated through br. 6/2026) and the [Uredba o bližim uslovima za paušalno oporezivanje](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/vlada/uredba/2017/94/1/reg) ("Sl. glasnik RS", br. 94/2019, with amendments).* When you register a preduzetnik in Serbia, you face a fundamental choice: paušalno oporezivanje (lump-sum taxation) or vođenje poslovnih knjiga (full bookkeeping). Most new entrepreneurs default to paušal because it's simpler and cheaper — and for many, that's the right call. But not always. Depending on your revenue level, expense structure, and growth plans, full bookkeeping can actually leave you with more money in your pocket. This guide compares both regimes side by side: how taxes are calculated, what obligations each imposes, where the break-even points are, and who genuinely benefits from each. --- ## The core difference in one sentence **Paušalac:** You pay taxes on a fictional income (paušalni prihod) that the Tax Authority assigns based on your activity code, location, and other factors — regardless of how much you actually earn. **Knjigaš:** You pay taxes on your actual profit — revenue minus documented business expenses — just like a traditional business. This single distinction drives everything else. When your actual expenses are low (as is common for IT freelancers working from home), the paušal system's fictional income is often lower than your real profit, making paušal cheaper. When you have significant legitimate expenses (office rent, employees, equipment, subcontractors), bookkeeping lets you deduct them, potentially reducing your tax base below what the paušal system would assess. --- ## Side-by-side comparison | Aspect | Paušalac | Knjigaš (bookkeeping) | |--------|----------|----------------------| | **Tax base** | Assessed paušalni prihod (fictional, set by Tax Authority) | Actual profit = revenue − documented expenses | | **Income tax rate** | 10% of paušalni prihod | 10% of actual profit | | **Social contributions** | ~35.05% of paušalni prihod (PIO 24%, health 10.30%, unemployment 0.75%) | ~35.05% of actual profit (same rates, but base differs) | | **Total tax burden** | ~45.05% of paušalni prihod | ~45.05% of actual profit | | **Revenue limit** | 6,000,000 RSD/calendar year | No limit | | **PDV (VAT) threshold** | 8,000,000 RSD rolling 12 months (same for both) | 8,000,000 RSD rolling 12 months | | **Bookkeeping obligation** | KPO knjiga only (revenue log) | Full double-entry bookkeeping (requires accountant) | | **Tax return** | None (Tax Authority issues rešenje) | Annual PPDG-1S return | | **Expense deduction** | Not allowed — the system assumes standardized expenses | All legitimate business expenses deductible with documentation | | **Accountant required?** | No (but recommended for complex situations) | Yes — practically mandatory | | **Monthly accountant cost** | €0–50 (optional advisory) | €80–200+ depending on transaction volume | | **Tax determination** | Tax Authority issues rešenje automatically each January | You (or your accountant) calculate and file | | **First-year discount** | 50% reduction of assessed base | No automatic discount (but startup expenses are deductible) | | **Annual base increase cap** | Max 10% year-over-year (through end of 2027) | No cap — based on actual profit | | **Eligible activities** | Most services and crafts; excluded: wholesale/retail, hospitality, finance, advertising, market research | All activities | | **Can register for PDV voluntarily?** | No — PDV registration terminates paušal status | Yes | --- ## How taxes actually work: paušalac The Tax Authority calculates your paušalni prihod (assessed lump-sum income) using a formula defined in the Uredba o bližim uslovima, kriterijumima i elementima za paušalno oporezivanje. The formula considers: - **Average wage** in your municipality - **Activity code coefficient** — each šifra delatnosti has a multiplier (e.g., IT consulting might be 2.5x, translation 1.2x) - **Corrective factors:** registered location zone, entrepreneur's age (under 30 gets 0.7 coefficient, under 55 gets 0.9), time since registration (first year: 0.5 coefficient), disability status The result is your monthly paušalni prihod. Your taxes are 45.05% of this figure. You pay the same amount every month regardless of whether you earned €10,000 or €0 that month. **Example — IT consultant in Belgrade, activity code 6201, 3rd year of operation:** - Assessed monthly paušalni prihod: ~45,000 RSD (varies, this is illustrative) - Monthly income tax (10%): ~4,500 RSD - Monthly PIO (24%): ~10,800 RSD - Monthly health (10.30%): ~4,635 RSD - Monthly unemployment (0.75%): ~338 RSD - **Total monthly obligation: ~20,273 RSD (~€173)** - **Annual total: ~243,270 RSD (~€2,076)** If this entrepreneur actually earns €48,000/year (€4,000/month), their effective tax rate is approximately **4.3%** of gross revenue. This is why paušal is so attractive for high-earning, low-expense service businesses. --- ## How taxes actually work: knjigaš A knjigaš pays taxes on **actual profit** — revenue minus all legitimate, documented business expenses. The rates are the same (10% income tax + 35.05% contributions), but the base is different. **Example — same IT consultant, same €48,000/year revenue, minimal expenses:** - Annual revenue: €48,000 (~5,620,000 RSD) - Documented expenses: €3,600/year (internet, phone, minor equipment, co-working occasionally) = ~421,000 RSD - Taxable profit: 5,199,000 RSD - Income tax (10%): 519,900 RSD - Social contributions (35.05%): 1,822,250 RSD - **Total annual obligation: ~2,342,150 RSD (~€20,000)** Effective tax rate: approximately **41.7%** of gross revenue. Compare that to the paušalac's 4.3%. The difference is staggering — approximately **€18,000/year** more in taxes for the same revenue, simply because the knjigaš pays on actual profit while the paušalac pays on a much lower assessed base. **Note on contribution caps:** Social contributions have a maximum monthly base (currently ~5x the average wage, roughly 600,000 RSD/month). For very high earners, this cap limits the absolute amount of contributions. But for most preduzetnici earning under €100K/year, the cap doesn't come into play. --- ## When knjigaš actually wins: the expense scenario The math changes dramatically when significant business expenses enter the picture. **Example — marketing consultant with high expenses:** - Annual revenue: €60,000 (~7,020,000 RSD) - Paušal status: **Not available** — revenue exceeds 6M RSD limit. Must be knjigaš. - Documented expenses: office rent €6,000, subcontractors €15,000, travel €4,000, equipment €3,000, other €2,000 = €30,000 (~3,510,000 RSD) - Taxable profit: 3,510,000 RSD - Total tax obligation: ~1,587,000 RSD (~€13,560) - Effective rate: ~22.6% of gross revenue In this case, the entrepreneur has no choice (revenue exceeds 6M), but the high expense ratio makes bookkeeping manageable — deducting €30,000 in real expenses significantly reduces the tax base. **Another example — low-revenue knjigaš with high expenses:** - Annual revenue: €25,000 (~2,925,000 RSD) - Could be paušalac (under 6M) — let's compare both options - Documented expenses: €12,000 in subcontractor costs, €3,000 in equipment = €15,000 (~1,755,000 RSD) - As knjigaš: taxable profit = 1,170,000 RSD → total tax ~528,585 RSD (~€4,517) - As paušalac: assessed base ~45,000 RSD/month → total tax ~243,270 RSD (~€2,076) Even with 60% of revenue going to expenses, paušal is still cheaper because the assessed base is so low. The knjigaš option only starts winning when expenses are very high AND the assessed paušal base would be comparable to or higher than actual profit. --- ## Break-even analysis: when to switch The break-even point depends heavily on your specific paušalni prihod (which varies by activity, location, and personal factors). But as a general guide: | Scenario | Paušal better? | Knjigaš better? | |----------|---------------|-----------------| | Revenue < 6M RSD, low expenses (< 20% of revenue) | Almost always | No | | Revenue < 6M RSD, moderate expenses (20–50%) | Usually | Unless assessed base is unusually high | | Revenue < 6M RSD, very high expenses (> 60%) | Compare carefully | May win if profit < paušalni prihod | | Revenue > 6M RSD | Not eligible | Only option | | Need to hire employees | Not practical | Necessary | | Need PDV (VAT) registration | Incompatible | Required | | Want to deduct equipment, travel, rent | Not possible | All deductible | | Multiple activity types incl. restricted ones | May be ineligible | No restrictions | **The simple heuristic:** If you're a service-based business earning under €50,000/year with low overhead, paušal is almost certainly cheaper. If you have significant documented expenses (subcontractors, office, equipment) that exceed 50–60% of revenue, or if you're approaching/exceeding the 6M limit, run the numbers for your specific situation. --- ## Obligations comparison: the real daily difference Beyond tax amounts, the two regimes impose very different administrative burdens: ### As a paušalac, you must: - Maintain a [KPO knjiga](/articles/kpo-book) (10 minutes per invoice) - Make [4 monthly bank transfers](/articles/tax-payments) (5 minutes with templates) - Track [revenue vs 6M and 8M limits](/articles/revenue-limits) - That's it. No annual tax return, no expense documentation, no accountant. ### As a knjigaš, you must: - Maintain full double-entry bookkeeping (practically requires an accountant) - Collect and organize all expense receipts and invoices - File the annual PPDG-1S tax return - Maintain poslovne knjige (business books) per accounting standards - Potentially file periodic PDV returns (if VAT-registered) - Track depreciation of assets - Maintain a register of fixed assets The administrative burden of bookkeeping costs both money (€80–200/month for an accountant) and time (organizing documents, communicating with your accountant, reviewing statements). --- ## Switching between regimes ### Paušalac → Knjigaš This happens either voluntarily or by force: - **Forced:** Your revenue exceeds 6M RSD. You transition to bookkeeping from July 1 (if exceeded in H1) or January 1 of next year (if H2). - **Voluntary:** You can choose to switch at any time by notifying the Tax Authority. Reasons might include wanting to deduct expenses, needing PDV registration, or entering a restricted activity. ### Knjigaš → Paušalac If your previous year's revenue was under 6M RSD and you meet all eligibility criteria, you can apply for paušal status by **October 31** for the following year. The Tax Authority reviews your application and issues a decision. The transition isn't always smooth. Going from knjigaš to paušalac means you stop deducting expenses mid-stream, which can have implications for assets, ongoing contracts, and PDV obligations (if you were registered). Consult an accountant before switching. --- ## The DOO alternative (brief note) Some entrepreneurs outgrow the preduzetnik form entirely and register a DOO (društvo sa ograničenom odgovornošću — limited liability company). This is a separate legal entity with different tax treatment: 15% corporate profit tax + personal income tax on distributed profits (dividend tax 15%). The effective rate on distributed profits is approximately 25–28%, which can be lower than knjigaš rates for high-earning businesses — plus the DOO provides limited liability. A full DOO comparison is beyond this article's scope, but if you're earning above €70–80K and growing, it's worth modeling with an accountant. --- ## Key takeaways 1. **Paušal wins on simplicity and usually on cost** for service businesses under €50K/year with low expenses. The assessed base is typically far below actual income. 2. **Knjigaš wins when expenses are high** relative to revenue, or when you exceed the 6M limit, need PDV, or require expense deductions for business planning. 3. **The administrative burden gap is significant.** Paušal: 30 minutes/month, no accountant needed. Knjigaš: ongoing accountant relationship, document management, annual returns. 4. **Run the numbers for your specific situation.** The general heuristic is useful, but your actual paušalni prihod (which depends on activity code, municipality, and personal factors) determines the real comparison. 5. **Switching is possible but plan ahead.** Paušalac → knjigaš can be forced or voluntary. Knjigaš → paušalac requires an October 31 application and meeting all eligibility criteria. # Preduzmi vs Excel: Why Spreadsheets Break Down for Paušal Compliance Source: https://preduzmi.com/articles/preduzmi-vs-excel Published: 2026-03-18 > Feature-by-feature comparison of managing paušal obligations with spreadsheets versus Preduzmi. Learn where manual tracking fails and when a dedicated tool makes the difference. *Last updated: March 2026.* Most paušalci start with a spreadsheet. A Google Sheet with a few columns — invoice number, date, amount, running total. It works fine for the first few months. Then you issue an invoice in EUR and need to look up the NBS exchange rate for that specific date. Then you realize you've been tracking the wrong date (payment date instead of service date). Then you forget to update the rolling 12-month total and don't notice you're approaching the 8M PDV limit until your accountant mentions it in passing. Spreadsheets are powerful general-purpose tools. But paušal compliance has specific, rule-bound requirements that spreadsheets handle poorly — not because they can't, but because they depend entirely on you remembering every rule, every formula, every edge case, every time. This article compares managing your paušal obligations manually (spreadsheets, bank statements, mental checklists) versus using Preduzmi, a purpose-built tool for Serbian paušalci. --- ## Feature-by-feature comparison | Capability | Excel / Google Sheets | Preduzmi | |-----------|----------------------|----------| | **Invoice recording** | Manual entry: type invoice number, date, amount, client name. Copy-paste from your invoice document. | Upload PDF/DOCX — AI extracts all fields automatically. Review and confirm. Batch upload supported. | | **KPO knjiga generation** | Build your own KPO template. Manually number entries. Hope you maintain chronological order. | Auto-generated from confirmed invoices. Sequential numbering enforced. Chronological order guaranteed. Exportable. | | **Currency conversion** | Look up NBS middle rate on nbs.rs for each invoice date. Copy the rate. Multiply manually. Hope you used the right date. | Auto-fetches NBS rate for the service date. Shows it to you for confirmation. Calculates RSD amount automatically. | | **6M calendar-year limit** | Write a SUMIFS formula filtering by year. Remember to use service date, not issue date or payment date. Update formula if you add columns. | Real-time calculation displayed on dashboard. Color-coded progress bar. Includes draft invoices. | | **8M rolling 12-month limit** | Complex formula: sum all invoices where service date falls within the last 365 days. Recalculates only when you open the sheet. Easy to get wrong. | Calculated on every page load. Updates in real time as invoices are added or modified. Alert banner when approaching threshold. | | **Limit warnings** | You notice when you happen to look at the number and do the mental math. No alerts. | Automatic color-coded warnings: green → yellow → orange → red. Persistent alert banner when above 85% of either limit. | | **Tax payment tracking** | Separate sheet or mental checklist. Manually check bank statement each month for four payments. | Upload bank statements — auto-categorizes tax payments by treasury account number. Monthly compliance table shows paid/unpaid status per payment type. | | **Tax payment reminders** | Calendar reminder on your phone. You set it up once and hope it keeps working. | Dashboard shows current month's payment status. Alerts if past the 15th deadline with unfound payments. | | **Bank transaction import** | Download CSV/XML from bank. Open in Excel. Manually scan for relevant transactions. | Upload XML (Raiffeisen) or CSV (any bank). AI-assisted column mapping for CSV. Deduplication prevents double-counting. | | **Transaction deduplication** | Entirely your problem. Upload the same file twice — double entries. Overlapping date ranges — duplicates. | Automatic deduplication by reference number (primary) or date+amount (fallback). Duplicates flagged, never silently added. | | **Invoice-payment matching** | Manual: scroll through bank transactions, find the one that matches the invoice amount, mentally link them. | Manual linking in UI (click invoice → select matching transaction). Invoice status auto-updates to PAID. | | **Rešenje data management** | Remember the four monthly amounts. Update them in January. Keep the PDF somewhere you can find it. | Upload rešenje PDF — AI extracts amounts, BOP, treasury accounts. Stored per year. Historical amounts preserved. | | **Multi-year history** | Grows unwieldy. Separate tabs per year. Formulas break when you restructure. | All data in one place. Filter by year. Rolling calculations span years automatically. | | **Sharing with accountant** | Email the spreadsheet. Version confusion. "Which file is current?" | Export data or grant read access. Single source of truth. | | **Mobile access** | Google Sheets works on mobile but is painful to use for data entry. | Responsive web app. Check dashboard status from your phone in 10 seconds. | | **Data security** | Google Sheet — anyone with the link can view (if sharing settings are wrong). Local Excel file — no backup unless you set it up. | Per-user data isolation enforced at database level. Your data is never visible to other users. | | **Setup time** | 2–4 hours to build a decent template with formulas. Then ongoing maintenance. | Register, fill business profile (10 minutes or upload rešenje for auto-fill), start uploading invoices. | | **Cost** | Free (if using Google Sheets) or Excel license you already have. | Subscription (see pricing page). | --- ## Where spreadsheets actually work fine Let's be fair. For certain paušalci, a spreadsheet is genuinely sufficient: **You might not need Preduzmi if:** - You issue fewer than 3–4 invoices per month, all in RSD, to Serbian clients - Your revenue is well below 4M RSD and nowhere near either limit - You have a single bank account with simple transactions - You're comfortable with formulas and enjoy maintaining your spreadsheet - You already have a working system and zero compliance concerns In these cases, the marginal benefit of a dedicated tool may not justify the cost. A well-maintained Google Sheet with correct formulas does the job. **The spreadsheet breaks down when:** - You invoice in multiple currencies and need accurate NBS conversion per invoice - Your revenue is in the 4–7M RSD range where limit tracking is critical - You have transactions from multiple sources or banks - You want to verify tax payments against bank statements automatically - You've ever forgotten to update a formula after changing your spreadsheet structure - You've ever discovered a calculation error months after the fact --- ## The hidden cost of spreadsheet errors Spreadsheet compliance has a failure mode that purpose-built tools don't: **silent errors.** A broken formula, a wrong cell reference, a filter that excludes a row — these don't announce themselves. You discover them when: - The Tax Authority sends an inquiry because your KPO total doesn't match their records - You realize in November that you've been tracking issue dates instead of service dates, and your limit calculation is wrong - You find a duplicate entry that inflated your revenue tracking, causing unnecessary stress about limits - Your rolling 12-month calculation was using 12 calendar months instead of 365 days, and the actual figure is higher than you thought Each of these scenarios has appeared in paušalci community forums. They're not hypothetical — they're the predictable result of relying on manual processes for rule-bound calculations. The financial cost ranges from minor (penalty interest) to severe (unexpected PDV registration obligation discovered after the fact). A dedicated tool doesn't eliminate all risk, but it eliminates the category of risk that comes from building and maintaining your own compliance system. --- ## What Preduzmi doesn't replace Preduzmi is a tracking and compliance tool, not a full accounting system or a substitute for professional advice: - **It doesn't replace an accountant** for complex situations (switching to knjigaš, annual income tax obligations, independence test assessment) - **It doesn't file taxes for you** — you still make the four monthly bank transfers yourself - **It doesn't generate legally valid invoices** (in the first version) — you create invoices in your own tool/template and upload them to Preduzmi for tracking - **It doesn't provide legal advice** — when a situation requires interpretation of tax law, consult a professional Think of it as the tool that handles the routine 95% — accurate tracking, limit monitoring, payment verification, KPO generation — so that you and your accountant can focus on the 5% that actually requires judgment. --- ## Migration from spreadsheet to Preduzmi If you've been using a spreadsheet and want to switch: 1. **Export your existing invoices** from the spreadsheet 2. **Upload invoice files** (PDFs/DOCXs) to Preduzmi — the AI parser will extract the data, and you verify it matches your spreadsheet records 3. **For invoices without files,** create them manually in Preduzmi using the data from your spreadsheet 4. **Upload bank statements** to populate your transaction history 5. **Verify totals** — your Preduzmi dashboard totals should match your spreadsheet. If they don't, you've likely found an error in one system or the other (and now you can fix it). The migration is a one-time effort. Once your historical data is in Preduzmi, ongoing maintenance is uploading new invoices and bank statements as they occur. --- ## Key takeaways 1. **Spreadsheets work for simple cases** — few invoices, single currency, revenue well below limits. If that's you, keep your spreadsheet. 2. **Spreadsheets break down at scale and complexity** — multiple currencies, limit-adjacent revenue, multi-bank transactions, and the cumulative risk of formula errors. 3. **The core advantage of a dedicated tool is eliminating silent errors** — wrong dates, broken formulas, missed conversions, duplicate entries. These are the errors that cause real compliance problems. 4. **Preduzmi handles the routine compliance** (KPO, limits, currency conversion, tax payment tracking) so you can focus on your actual business. 5. **The cost comparison isn't just subscription vs free** — it's subscription vs the time spent maintaining formulas, the risk of undetected errors, and the potential cost of compliance failures. # The 2026 Paušalac Calendar: Every Deadline and First-Year Checklist Source: https://preduzmi.com/articles/calendar-checklist Published: 2026-03-16, updated 2026-08-21 > Month-by-month calendar of every recurring obligation for Serbian paušal entrepreneurs, plus a complete first-year setup checklist for new preduzetnici. *Last updated: August 2026. Covers all recurring obligations for paušalni preduzetnici in Serbia.* Being a paušalac is often described as "no bookkeeping required." That's technically true — you don't maintain double-entry books or file complex tax returns. But "no bookkeeping" doesn't mean "no obligations." There are monthly payments to make, a revenue book to maintain, revenue limits to watch, annual documents to review, and periodic registrations to renew. Miss any of them and you face penalty interest, compliance issues, or worse. This guide provides two things: a month-by-month calendar of every recurring obligation for established paušalci, and a complete first-year checklist for anyone who just registered their preduzetnik. --- ## Part 1: Monthly and annual calendar for established paušalci ### Every month **By the 15th — Pay your four tax obligations** The most important recurring task. Four separate bank transfers to four treasury accounts: 1. Porez na prihode (Income Tax) → account from your rešenje 2. PIO (Pension) → account from your rešenje 3. Zdravstveno (Health) → account from your rešenje 4. Nezaposlenost (Unemployment) → account from your rešenje All use model 97 and the BOP (poziv na broj) from your current year's rešenje. If you have dopunska delatnost (side business while employed), you pay only items 1 and 2. **Never carry over last year's BOP (reference number) into the new year.** The BOP changes annually with each new rešenje. Using the old one is the most common payment error and can leave your payment unallocated or attributed to the wrong person. **Continuously — Maintain your KPO knjiga** Record every issued invoice in your KPO (Book of Realized Turnover) as you issue it. Entries must be chronological by service date. Convert foreign-currency invoices to RSD at the NBS official middle rate — the rate *type* is prescribed (ZDP čl. 41 st. 2), the rate *date* is not, for a paušalac outside the VAT system. Common practice is the invoice date, or the supply date where the two differ; what matters is applying the same basis to every entry. The mechanics are in [the KPO guide](/articles/kpo-book). Don't batch-enter once a month — enter each invoice within a day or two of issuance. If the Tax Authority inspects and finds your KPO entries were all made on the same date, it raises questions. **Continuously — Monitor revenue limits** Track two numbers: - Calendar-year revenue total vs 6,000,000 RSD (paušal limit) - Rolling 12-month revenue total vs 8,000,000 RSD (PDV / VAT limit) Both are calculated from invoiced amounts (in RSD) by service date. The rolling 12-month figure changes daily as old invoices exit and new ones enter the window. --- ### January **Receive new rešenja from Poreska uprava** Typically delivered via ePorezi in the second half of January. Two documents: one for income tax, one for social contributions. These specify your new monthly payment amounts and new BOP for the year. **Action:** Review amounts (check the 10% annual cap — your obligation shouldn't increase by more than 10% vs last year unless you changed activity code or location). Update your bank payment templates with new amounts and BOP. The new amounts apply starting with the January payment (due February 15). **Your obligations can't increase by more than 10% year-over-year** under the current Uredba (extended through end of 2027), unless you changed your activity code or location. If the increase exceeds 10%, verify with Poreska uprava. **Review previous year's KPO totals** Before the year gets busy, verify your total KPO revenue for the prior year. Compare it against the 6M limit. If it was close, plan your invoicing cadence for the new year. --- ### February **First tax payment of the new year (for January)** Due by February 15. This is the first payment at the new rešenje amounts. Make sure you've updated templates with the new BOP. --- ### March-April **Ekološka taksa (Ecological fee)** The eko taksa is a local government fee paid annually. The deadline varies by municipality but is typically in **March or April.** The amount depends on your business size classification — micro-entrepreneurs usually fall in the lowest bracket (commonly 5,000-10,000 RSD). **Action:** Check with your local opština or on their website for the exact deadline and amount. Payment is usually made to the local government treasury account, not the republic-level accounts used for taxes. **Note:** Some municipalities send a rešenje for the eko taksa; others expect you to calculate and pay proactively. If you're unsure, call your local tax administration (LPA — lokalna poreska administracija). --- ### May 15 **Annual income tax return (Godišnji porez na dohodak građana) — if applicable** This is NOT the regular paušal tax — it is a separate annual tax on citizens whose total annual income from ALL sources exceeds a threshold set at three times the average annual salary (ZPDG čl. 87 st. 1). For income year 2025, filed in 2026, that threshold is **5,439,096 RSD**. See [the full guide to the annual income tax](/articles/annual-income-tax). **Most paušalci are NOT affected** because the tax base is your assessed paušalni prihod (from the rešenje), not your actual income. Since the assessed base is typically well below the threshold, the annual income tax doesn't apply. However, if you have significant income from **other sources** (rental income, capital gains, employment salary in addition to paušal) that pushes your total above the threshold, you may owe this tax. The deadline is **May 15 of the following year** (e.g., May 15, 2027 for 2026 income). **Action:** If your total income from all sources might exceed the threshold, consult a tax advisor. --- ### October 31 **Deadline to apply for paušal status (for new entrepreneurs or those returning)** If you want to be a paušalac starting January 1 of the next year, your application must be filed by **October 31** of the current year. This applies to: - Entrepreneurs currently on bookkeeping (knjigaš) who want to switch to paušal - Entrepreneurs returning from mirovanje (dormancy) who want paušal status **The October 31 deadline is firm.** If you miss it, you cannot switch to paušal status until the following year. For existing paušalci, no action is needed — your status continues automatically as long as you remain eligible. **For existing paušalci:** No action needed. Your paušal status continues automatically as long as you remain eligible. --- ### December **Year-end revenue check** Final chance to verify your calendar-year revenue against the 6M limit. If you're approaching the threshold, consider whether any December invoices can legitimately be deferred (i.e., if the service delivery genuinely falls in January). Do NOT backdate invoices or manipulate service dates — this constitutes fraud. **Prepare for new year:** - Ensure your KPO is complete and all invoices are recorded - New KPO numbering resets to 1 on January 1 - If using paper KPO, get a new book certified before January (or switch to electronic) --- ## Part 2: First-year checklist for new paušalci You just received your APR registration. Congratulations — you're a preduzetnik. Now what? Here's everything you need to do, in roughly chronological order. ### Week 1: Immediate post-registration **1. Verify your APR registration details** Check the APR portal (pretraga.apr.gov.rs) and confirm: - Business name is correct - Address is correct - Šifra delatnosti (activity code) is correct - Your PIB and matični broj are assigned APR registration triggers automatic registration with the Tax Authority, PIO Fund, and Statistical Office through the jednošalterski sistem (one-stop-shop). You should receive your PIB and matični broj within 1-2 days. **2. Open a business bank account (poslovni račun)** Visit a bank and open a tekući račun (current account) in the name of your preduzetnik. You'll need: - APR registration printout (rešenje o registraciji) - Personal ID (lična karta or passport) - PIB confirmation (APR printout or ePorezi) Most banks process this within 1-3 business days. Choose a bank based on fees, online banking quality, and whether they offer devizni račun (foreign currency account) if you'll invoice internationally. **3. Open a foreign currency account (if needed)** If you'll receive payments in EUR, USD, or other currencies, open a devizni račun at the same bank. Some banks open it automatically alongside the dinarski račun; others require a separate request. **4. Register on the ePorezi portal** Go to eporezi.purs.gov.rs. You'll need a kvalifikovani elektronski sertifikat (qualified electronic certificate) — either from your čipovana lična karta (ID card with chip, activated at MUP) or from a commercial certificate provider. ePorezi is where your rešenja will be delivered and where you can check your tax account status. Set it up now rather than scrambling later. ### Week 2-4: Tax setup **5. Wait for your rešenje (tax decision)** After APR registration, the Poreska uprava should issue your rešenje within **48 hours** via ePorezi. This document tells you: - Your monthly tax and contribution amounts - The BOP (payment reference number) - The treasury account numbers If the rešenje doesn't appear within a week, contact your local Poreska uprava office. **6. Understand your first-year tax discount** **New paušalci receive a 50% reduction in their assessed paušalni prihod for the first year.** This means your monthly obligations in year 1 are approximately half of what they'll be in year 2. The discount is applied automatically — you don't need to request it. Plan for year-2 amounts roughly doubling. **7. Set up payment templates** In your bank's online banking system, create four payment templates — one for each monthly obligation. Pre-fill all static fields (recipient accounts, model 97, BOP, amounts). This turns your monthly tax payment into a 5-minute task. **8. Make your first tax payment** Your first payment is due by the **15th of the month following your registration month.** If you registered on March 20, your first payment (for March, prorated) is due April 15. For the registration month itself, payments are prorated based on the number of days remaining in the month. Your rešenje should specify the first month's prorated amounts. ### Month 1-2: Operations setup **9. Set up your KPO knjiga** Choose paper or electronic format: - **Paper:** Buy a pre-formatted KPO book, get it certified (overena) at your local Poreska uprava - **Electronic:** Use a spreadsheet, accounting app, or dedicated tool. No certification needed. Your first entry goes in when you issue your first invoice. **10. Create your invoice template** Prepare a standard invoice template with all mandatory elements: - Your full business name, address, PIB, matični broj - Bank account / IBAN - Space for: invoice number, issue date, service date, client details, description, amount - The note: "Nije u sistemu PDV-a na osnovu člana 33. Zakona o PDV-u." **11. Understand which activities you can perform** Your registered šifra delatnosti is your primary activity, but you can legally perform **any activity** that isn't regulated (requiring special permits) without registering it additionally. You don't need to register every side service — just ensure your primary activity code reflects your main business. **12. Register for CROSO health insurance (if needed)** APR registration should automatically register you with the PIO Fund and health insurance (RFZO) through the jednošalterski sistem. However, activating your health booklet (zdravstvena knjižica) may require a visit to your local RFZO branch with proof of registration and first contribution payment. ### Ongoing: First-year habits **13. Invoice discipline** Issue invoices promptly when services are delivered. Record each one in your KPO immediately. Convert foreign currencies at the NBS official middle rate (ZDP čl. 41 st. 2); no rule fixes which date's rate a non-VAT paušalac uses, so pick the invoice date or the supply date and stay with it. **14. Revenue tracking from day one** Start tracking your cumulative revenue against both limits (6M calendar year, 8M rolling 12 months) from your very first invoice. Don't wait until you think you're getting close — the habit of tracking prevents surprises. **15. Keep all documents** Maintain organized records of: - All issued invoices (PDF copies) - KPO knjiga entries - Tax payment confirmations (bank receipts) - Rešenja from Poreska uprava - Client contracts - APR registration documents The Tax Authority can inspect records for the current year plus up to 5 prior years. Digital copies are fine for most documents, but keep originals of rešenja and registration documents. **16. Check ePorezi after 3 months** After your first few payments, log into ePorezi and check your "stanje na kartici" (tax account status). Verify that all payments are properly attributed. Catching errors early is far easier than fixing them later. --- ## Quick reference: annual deadlines at a glance | When | What | Details | |------|------|---------| | **15th of every month** | 4 tax payments | Income tax, PIO, health, unemployment. For the previous month. | | **Continuously** | KPO entries | Record each invoice when issued. Chronological order. | | **January** | Receive new rešenja | Via ePorezi. Update payment templates. | | **March-April** | Eko taksa | Annual ecological fee to local government. Check local deadline. | | **May 15** | Annual income tax return | Only if total income from all sources exceeds 5,439,096 RSD (2025 income, ZPDG čl. 87 st. 1). Most paušalci: not applicable. | | **October 31** | Paušal application deadline | Only for new applicants or those returning to paušal. Existing paušalci: no action. | | **December** | Year-end review | Verify KPO totals, check 6M limit, prepare for new year. | --- ## Key takeaways 1. **Monthly discipline is everything.** Four payments by the 15th, KPO entries with each invoice, continuous limit tracking. Build the habit and it takes 30 minutes per month total. 2. **January is your annual reset.** New rešenje → new amounts → new BOP → update templates. Don't carry over last year's reference numbers. 3. **First-year paušalci get a 50% tax discount.** Enjoy it, but plan for year-2 amounts roughly doubling. 4. **The ePorezi portal is your friend.** Check it quarterly to verify payments are correctly attributed. Prevention beats correction. 5. **Keep everything for 5+ years.** Invoices, KPO, payment receipts, rešenja, contracts. Digital copies are fine. 6. **When in doubt, ask early.** A 30-minute consultation with an accountant about something you don't understand costs far less than fixing a mistake discovered during an inspection 2 years later. # Invoicing Foreign Clients as a Serbian Paušalac Source: https://preduzmi.com/articles/foreign-invoicing Published: 2026-03-16, updated 2026-08-21 > Complete guide to invoicing foreign clients: mandatory fields, currency conversion, the PDV exemption, the double-count trap, and practical banking tips for Serbian paušal entrepreneurs. *Last updated: August 2026. Reflects current invoice requirements under Serbian law for non-VAT entrepreneurs.* Most Serbian paušalci in the IT and creative sectors earn the majority — or all — of their income from foreign clients. This creates a set of practical challenges that domestic-only paušalci never face: invoicing in foreign currencies, converting to dinars at the correct rate, navigating the place-of-supply rules for PDV exemption, and avoiding the notorious banking issue where the Tax Authority sees your revenue counted twice. This guide walks through everything you need to know about issuing invoices to foreign clients, from mandatory fields to currency conversion, from the "nije u sistemu PDV" rule to the double-count trap that has triggered many unnecessary Tax Authority inquiries. --- ## What must a paušalac's invoice contain? Serbian law prescribes mandatory elements for invoices (račun / faktura) issued by entrepreneurs. Since paušalci are **not in the VAT system**, the requirements come from the [Zakon o računovodstvu](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2019/73/5/reg) (Accounting Law, "Sl. glasnik RS", br. 73/2019) and the Zakon o trgovini (Trade Law) rather than the VAT-specific Article 42. Every invoice you issue must include: ### Your business details (issuer) - **Poslovno ime** — your full registered business name (e.g., "MARKO MARKOVIĆ PR PROGRAMIRANJE BEOGRAD") - **Sedište** — your registered business address - **PIB** — your Tax Identification Number - **Matični broj** — your APR registration number - **Tekući račun / IBAN** — your bank account for payment (domestic account number for Serbian clients, IBAN for international clients) ### Client details (recipient) - **Full company name** — the legal entity name of your client - **Address** — registered address of the client - **Company registration number or VAT ID** — if applicable in their country - **Country** — especially important for the PDV place-of-supply determination ### Invoice specifics - **Redni broj računa** — sequential invoice number. Must be unique and sequential within the calendar year. Common formats: "2025-001", "001/2025", "INV-2025-001". The numbering resets each January 1. - **Datum izdavanja** — date of issue (when you created the invoice) - **Datum prometa** — date of service delivery or goods supply. This is the **accrual date** that determines which period the revenue counts toward. If the service was delivered over a period (e.g., monthly retainer for March), this is typically March 31. - **Rok plaćanja** — payment deadline (e.g., "Net 30", or a specific date). Optional but standard practice. - **Description of services/goods** — what you provided. Can be brief: "Software development services, March 2025" or more detailed with line items. Include quantity and unit price if applicable. - **Total amount** — the total sum with the currency clearly stated (e.g., "€3,000.00" or "3,000.00 EUR") ### The critical non-VAT notation Since paušalci are not registered for PDV (VAT), your invoice must include a note stating this. The standard formulation is: > **"Nije u sistemu PDV-a na osnovu člana 33. Zakona o PDV-u."** > (Not in the VAT system pursuant to Article 33 of the VAT Law.) This note is not optional — it's legally required. And the converse rule is equally important: **never show a VAT amount on your invoice.** If you accidentally include a line like "PDV 20%: €600" on your invoice, you create a legal obligation to remit that VAT to the state — even though you're not a VAT payer. The Tax Authority has been known to enforce this strictly. No VAT line, no VAT percentage, no VAT total. Your invoice total is the total. **Never include a VAT line on your invoice.** Even if added by mistake, showing a VAT amount creates a legal obligation to remit that VAT to the state — regardless of your non-VAT status. The Tax Authority enforces this strictly. For foreign clients, you can add an English equivalent beneath the Serbian text: > *The issuer is not registered for VAT (PDV) under Article 33 of the Serbian VAT Law.* ### Stamp and signature A company stamp (pečat) has **not been mandatory** in Serbia since 2017. You may include one if your client expects it (some foreign companies are accustomed to seeing stamps on Serbian documents), but it has no legal significance. A signature (handwritten, facsimile, or electronic) is sufficient. For electronic invoices, a typed name serves as the identification mark (identifikaciona oznaka) under the Zakon o računovodstvu. --- ## Invoicing in foreign currency: what's allowed Paušalci can issue invoices in **any currency** — EUR, USD, GBP, CHF, or any other. There is no legal requirement to invoice in dinars. In practice, almost all invoices to foreign clients are issued in EUR or USD. The invoice shows the foreign-currency amount; the client pays in that currency to your foreign-currency bank account (devizni račun); and the bank eventually converts it to dinars. However, for all Serbian tax and record-keeping purposes — your KPO knjiga, your revenue limit calculations, your official turnover — the amount must be expressed in **Serbian dinars (RSD)**. The conversion has two halves, and they do not have the same standing: which *rate* you use is prescribed by law, which *day's* rate you use is not. **The rate type is prescribed; the date is a convention.** For bookkeeping and statistics the law requires the NBS **official middle rate** — *zvanični srednji kurs* — under Zakon o deviznom poslovanju čl. 41 st. 2, and using a different rate is a prekršaj. Which day's middle rate applies is nowhere prescribed for a paušalac outside the PDV system: ZPDV čl. 22 binds VAT payers, the Zakon o računovodstvu excludes him (čl. 2 t. 3 defines *preduzetnici* as those who keep double-entry books), and the KPO rulebook lays down no conversion rule at all. Converting at the **datum prometa** is settled practice rather than a rule — so pick one convention, apply it to every invoice, and keep it consistent year to year. This site uses the datum prometa throughout; see [foreign-currency inflows](/articles/foreign-currency-inflows) for the same point on the banking side. What is never right is the bank's own conversion rate, or a figure from a random currency-converter site. That half the law does settle. ### Step-by-step conversion example 1. You issue invoice #2025-015 to a German client for €4,000 2. Datum prometa (service date): May 20, 2025 3. NBS middle rate on May 20, 2025: 117.42 RSD/EUR 4. KPO entry: 469,680 RSD (4,000 × 117.42) 5. Your 6M calendar-year limit now includes this 469,680 RSD 6. Your 8M rolling 12-month limit also includes this 469,680 RSD What the bank actually credits to your RSD account when the client pays (maybe 2 weeks later, at a different rate, minus bank fees) is **irrelevant** for these calculations. ### Where to find the NBS middle rate The official source is the NBS website (nbs.rs → "Kursna lista"). For a given date, you need the "Srednji kurs" (middle rate) row for your currency. For programmatic access, the unofficial API at `kurs.resenje.org` provides the same NBS data in a developer-friendly format. While convenient, for tax purposes you should verify the rate against the official NBS publication, especially for large invoices. --- ## The double-count trap This is the single most anxiety-inducing issue for paušalci who invoice in foreign currency, and it comes up constantly in forums and community discussions. ### What happens Here's the sequence: 1. Your German client sends €4,000 to your EUR devizni račun at Raiffeisen bank on June 5. 2. The bank records an incoming transaction: +€4,000 (credit to your EUR account). 3. A few days later, you convert the EUR to RSD. The bank records: -€4,000 (debit from EUR account) and +466,000 RSD (credit to your RSD account, at the bank's conversion rate). 4. Your annual bank statement now shows **three transactions** related to this single invoice: the EUR credit, the EUR debit, and the RSD credit. When the Tax Authority reviews bank data (which they can access from the bank), they might initially see the incoming €4,000 (converted to ~469,000 RSD at NBS rates) **plus** the 466,000 RSD deposit — and calculate your revenue as ~935,000 RSD from a single €4,000 invoice. **The double-count trap can make your revenue appear twice as large.** When the Tax Authority cross-references bank data, they may see both the foreign currency deposit and the RSD conversion as separate income — triggering an inquiry even though you reported correctly. ### Why it matters If the Tax Authority cross-references bank data against your KPO and sees bank deposits that appear to significantly exceed your KPO total, this triggers a flag. The mismatch between "apparent bank revenue" and "declared KPO revenue" can generate an inquiry letter (zahtev za pojašnjenje) asking you to explain the discrepancy. ### How to protect yourself The solution is documentation clarity: 1. **Your KPO records the correct single amount:** 469,680 RSD (based on NBS rate at service date). This is your revenue. Period. 2. **Keep all invoices on file** matching each KPO entry. The Tax Authority can reconcile: Invoice #015 → KPO entry #15 → bank deposit. 3. **If you receive an inquiry**, explain that the bank statement reflects two movements (foreign currency in, conversion to RSD) for a single business transaction, and point to the matching invoice and KPO entry. 4. **Consider converting currency promptly** after receiving payment, to minimize the window where your EUR account shows a balance that might be counted as "additional" revenue. 5. **Maintain a simple reconciliation document** (even a spreadsheet) mapping each invoice to the specific bank transaction(s) it corresponds to. This isn't legally required but dramatically speeds up any inspection. The double-count issue is well-known at the Tax Authority and resolved easily with proper documentation. It's not a legal problem — it's an administrative confusion that good record-keeping prevents. --- ## Place of supply and the PDV exemption for foreign services This section matters for the 8-million PDV threshold specifically. Understanding it can mean the difference between mandatory VAT registration and staying safely under the limit. ### The basic rule Under Article 12 of the Zakon o PDV, the **place of supply** (mesto prometa) for services provided to a foreign legal entity (a company) is the country where the recipient is established — not Serbia. This means such services are treated as supplied outside Serbia for PDV purposes. ### What this means for the 8M limit Services where the place of supply is outside Serbia **do not count** toward the 8,000,000 RSD PDV threshold. If you provide software development services exclusively to a company in Germany, those services are "supplied" in Germany, and the revenue from them doesn't enter the 8M calculation. However — and this is critical — this same revenue **does count** toward the 6,000,000 RSD paušal calendar-year threshold. The exemption applies only to the PDV limit, not the paušal limit. **Foreign-service revenue is exempt from the 8M PDV limit but still counts toward the 6M paušal limit.** Many paušalci confuse the two thresholds. Exceeding 6M means losing paušal status — even if all your clients are foreign. ### When the exemption applies The exemption applies when: - You provide **services** (not goods) to a **legal entity** (company, not an individual) - The recipient is **established outside Serbia** (has their business seat in another country) - The service type falls under the general B2B rule (most IT, consulting, marketing, design, translation services qualify) ### When the exemption does NOT apply The exemption generally does not apply to: - Services related to **immovable property** located in Serbia - **Cultural, artistic, sporting, educational, or entertainment** services physically performed in Serbia - Services provided to **individuals** (B2C) rather than businesses - **Transport services** where the supply occurs partly in Serbia ### A practical scenario You're a web developer earning €4,000/month from a US client and €1,500/month from a Serbian client: - **6M paušal limit (calendar year):** Counts both. That's approximately 5,500 × 117 = 643,500 RSD/month, or ~7,722,000 RSD/year. You'd exceed the 6M paušal limit. - **8M PDV limit (rolling 12 months):** Only the Serbian client's revenue counts (the US client's services are "supplied" in the US). That's ~1,500 × 117 = 175,500 RSD/month, or ~2,106,000 RSD/year. Well under 8M. In this scenario, you'd lose paušal status (exceeding 6M) but wouldn't need to register for PDV (under 8M excluding foreign services). ### The documentation requirement To claim the place-of-supply exemption, you should be able to demonstrate: - The client is a foreign legal entity (their registration documents, or at minimum, a verifiable company name and foreign address on your invoices) - The services were performed for the client's business purposes (a contract or service agreement helps) - The services fall under the general B2B rule You don't need to file a special form or get pre-approval. But if the Tax Authority questions whether you should be PDV-registered, you need to show that your foreign-service revenue legitimately doesn't count toward the 8M threshold. --- ## Invoice template for foreign clients Here's a standard invoice structure for a Serbian paušalac invoicing a foreign client: ``` [YOUR BUSINESS LETTERHEAD / LOGO] INVOICE / FAKTURA Invoice No: 2025-015 Date of issue (Datum izdavanja): May 22, 2025 Date of service (Datum prometa): May 20, 2025 Payment due: June 21, 2025 FROM: Marko Marković PR Programiranje Beograd Knez Mihailova 42, 11000 Beograd, Srbija PIB: 112233445 Matični broj: 66554433 IBAN: RS35265000000123456789 SWIFT: RZBSRSBG TO: TechCorp GmbH Friedrichstraße 123, 10117 Berlin, Germany VAT ID: DE123456789 DESCRIPTION AMOUNT ───────────────────────────────────────────────── Software development services, €4,000.00 May 1-20, 2025 ───────────────────────────────────────────────── TOTAL: €4,000.00 Payment terms: Bank transfer to the IBAN above. Please include invoice number in payment reference. Nije u sistemu PDV-a na osnovu člana 33. Zakona o PDV-u. (The issuer is not registered for VAT under Article 33 of the Serbian VAT Law.) ________________________ Marko Marković ``` Adjust as needed — there's no mandated visual format, only required content. Some paušalci add additional elements: purchase order numbers (if the client requires them), hourly breakdowns, project references. All fine as long as the mandatory elements are present. --- ## Receiving payment: practical banking notes ### Bank accounts for foreign payments To receive foreign-currency payments, you need a **devizni račun** (foreign currency account) at your Serbian bank. Most banks offer EUR and USD accounts; some offer GBP and CHF. Opening one is straightforward — just request it from your existing business bank. When your client's payment arrives, it lands in your devizni račun. You then convert to RSD at your convenience (some banks auto-convert, others let you hold foreign currency and convert manually). The conversion rate is the bank's own rate, which is less favorable than the NBS middle rate. ### SWIFT fees and correspondent bank charges International transfers often incur SWIFT messaging fees and correspondent bank charges. A €4,000 payment might arrive as €3,980 after fees. The "missing" €20 is a banking cost, not a revenue reduction — your KPO still records the full invoiced amount (€4,000 converted at NBS rate). The fee difference is simply a cost of doing business that paušalci absorb. **SWIFT fees don't reduce your recorded revenue.** Your KPO always records the full invoiced amount at the NBS rate, regardless of how much actually arrives after bank fees. The fee difference is a business cost, not a revenue adjustment. ### Payment platforms (Wise, Payoneer, Deel) Many paušalci receive payments through Wise (formerly TransferWise), Payoneer, or similar platforms rather than direct bank transfers. This is generally fine, with a few notes: - The payment still constitutes business revenue regardless of the receiving channel - Your KPO records the **invoiced amount** at the NBS rate on the service date — not the amount that actually arrives after platform fees - When you transfer from Wise/Payoneer to your Serbian bank, the bank sees an incoming transfer that should match (approximately) one of your invoices - Keep records of platform transactions for reconciliation purposes --- ## Key takeaways 1. **Mandatory invoice elements:** business name, PIB, matični broj, address, IBAN, invoice number, issue date, service date, client details, description, total amount, and the "nije u sistemu PDV" note. 2. **Never show VAT on your invoice.** You're not a VAT payer. Showing a VAT line creates a legal obligation to remit it. 3. **Convert to RSD at the NBS middle rate** on the service date for your KPO and limit calculations. Not the bank rate, not the payment-date rate. 4. **The double-count trap** is an administrative issue, not a legal one. Good documentation (matching invoices → KPO → bank transactions) resolves it instantly. 5. **Foreign-service revenue may not count toward the 8M PDV threshold** if the place of supply is outside Serbia. But it always counts toward the 6M paušal threshold. 6. **Keep your invoices, contracts, and a simple reconciliation.** When an inquiry comes — and for active paušalci billing foreign clients, it eventually will — clear records turn a potential headache into a 10-minute administrative exercise. # Health, Sick Leave, and Pension Rights for Serbian Paušalci Source: https://preduzmi.com/articles/health-pension Published: 2026-03-16, updated 2026-08-21 > What your monthly contributions actually buy: RFZO health coverage, sick leave rules (the 30-day gap), maternity benefits, pension accrual, and where the system falls short. *Last updated: August 2026. Reflects current rights under the [Zakon o zdravstvenom osiguranju](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2005/107/4/reg) ("Sl. glasnik RS", br. 107/2005, with amendments), the [Zakon o penzijskom i invalidskom osiguranju](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2003/34/1/reg) ("Sl. glasnik RS", br. 34/2003, with amendments), and the Zakon o zdravstvenoj zaštiti.* Every month you transfer money to three social insurance accounts: pension (PIO), health (zdravstveno), and unemployment (nezaposlenost). For many paušalci, especially those early in their careers, these feel like abstract taxes — money that disappears into government accounts with no visible return. But these contributions do buy you something: health coverage, a pension that's accruing right now, sick leave rights (with significant limitations), and maternity benefits. The problem is that most paušalci don't know exactly what they're entitled to, how to access it, or where the gaps are. Some discover their pension years weren't properly recorded only when they try to retire. Others learn about the sick leave rules only when they get seriously ill and realize the first month is entirely on them. This guide explains what your contributions actually cover, how to verify you're getting what you're paying for, and where the system falls short. --- ## Health insurance: what you get ### Basic coverage Your monthly doprinos za zdravstveno osiguranje (health insurance contribution) gives you access to Serbia's public healthcare system through the RFZO (Republicki fond za zdravstveno osiguranje — Republic Health Insurance Fund). This covers: - **Primary care** at your assigned dom zdravlja (health center) — GP visits, basic diagnostics, referrals - **Specialist consultations** at public hospitals and clinics (with referral from GP) - **Hospital treatment** including surgery, emergency care, and intensive care - **Prescription medications** on the RFZO's positive list (partially or fully covered) - **Maternity care** — prenatal visits, delivery, postnatal care - **Dental care** — basic procedures (extractions, some fillings) at public dental clinics ### What's NOT covered (or barely covered) - **Private healthcare** — your RFZO insurance doesn't cover private clinics or hospitals. Many paušalci use private healthcare anyway and pay out of pocket. - **Advanced dental work** — crowns, bridges, implants, orthodontics are not covered or have minimal coverage - **Certain medications** — drugs not on the positive list must be purchased at full price - **Specialized treatments abroad** — only covered in exceptional cases with prior RFZO approval - **Eyeglasses, contact lenses** — minimal or no coverage for adults ### How to verify your coverage is active Your health insurance status can be checked at: 1. Your local RFZO branch (filijala) — bring your ID and PIB 2. The RFZO website: rfzo.rs (limited online functionality) 3. Your dom zdravlja — they can verify your insurance status in their system You should receive a **zdravstvena knjižica** (health booklet) or its electronic equivalent. This is your proof of insurance. To activate or renew it, visit your RFZO branch with proof of paid contributions (bank receipts or ePorezi printout). **Paying contributions does not automatically mean your coverage is active.** Some paušalci discover their health booklet has expired or their status shows as "inactive" despite regular payments. This happens when the Tax Authority hasn't forwarded payment confirmation to RFZO, or when the initial registration step was missed. If this happens, visit RFZO with your payment receipts. ### The overena knjižica ritual Historically, paušalci had to get their health booklet certified (overena) every month or quarter by bringing payment receipts to RFZO. This requirement has been relaxed in recent years with electronic verification between systems, but some RFZO branches still operate on the old process. Check with your local branch what they require. --- ## Sick leave: the rules that surprise everyone ### How sick leave works for paušalci This is where paušalci are most disadvantaged compared to employed persons. The rules: **The first 30 days of sick leave are self-funded.** Nobody compensates you for them — RFZO's sick-leave compensation starts on day 31. Registering a prekid (mirovanje) at APR documents the period of incapacity and suspends the contributions obligation (ZDOSO čl. 50), but it does not close that 30-day gap. **Day 31 onward: RFZO compensation.** Starting from the 31st day of continuous illness, the RFZO begins paying sick leave compensation. The amount is calculated as **65% of the base** on which you've been paying contributions (your paušalni prihod from the rešenje, not your actual income). **Critical illness exception:** For certain serious conditions (cancer, transplant, complications during pregnancy), RFZO compensation starts from day 1 at a higher rate. These cases require specific medical documentation and RFZO approval. ### What a registered prekid changes **A registered prekid suspends the obligation to pay social contributions.** ZDOSO čl. 50 st. 1: *"obaveza plaćanja doprinosa miruje u periodu u kojem ne obavlja delatnost"* — and stav 2 of the same article expressly allows you to keep paying them anyway. That election matters here more than anywhere else: voluntary payment is what keeps your pension staž accruing and your health cover running through a long illness, so treat it as a decision, not a formality. Two things bound it: - **The suspension follows the registration, not the illness.** Simply not working suspends nothing. Until APR registers the prekid, the contributions run exactly as before. - **The tax line is unsettled.** We could locate no provision that suspends *porez na prihode od samostalne delatnosti* during a prekid — and none that keeps it running either. Do not assume in either direction: once APR has registered the prekid, confirm your monthly tax obligation with Poreska uprava. The full mechanics of the procedure are in [mirovanje vs brisanje](/articles/mirovanje-vs-brisanje). **If a maternity benefit is involved, contact RFZO before you file.** APR says this in its own guidance: the prekid start date you register determines how the benefit is calculated, and it is the one part of the filing that cannot be corrected afterwards. ### The practical problem The 30-day self-funded gap is brutal for freelancers. If you break your arm and can't work for 3 weeks, you get nothing. Your client isn't paying you, RFZO doesn't start before day 31, and unless a prekid is registered your contributions keep running as usual. For this reason, many paušalci: - Maintain an emergency fund covering at least 2-3 months of expenses - Purchase supplementary private health insurance with income-loss riders - Work through minor illnesses rather than formally registering sick leave (which, while understandable, means those days aren't documented if the condition worsens) ### Sick leave process step by step 1. **Visit your doctor** at the dom zdravlja. Obtain a doznaka (sick leave certificate) specifying the diagnosis, expected duration, and recommendation for work incapacity. 2. **Register a prekid (mirovanje) at APR.** Submit a request to suspend your business activity for the period of illness — this can be done online through APR's portal. Nothing is suspended until the registration goes through. 3. **Decide what to do about the contributions.** From the registered prekid, ZDOSO čl. 50 suspends the obligation to pay them, and the same article lets you keep paying voluntarily — which is what preserves your pension staž and health cover. For the tax line, confirm your monthly obligation with Poreska uprava: no provision we could locate settles it either way. 4. **If illness extends beyond 30 days,** submit documentation to RFZO for compensation. Your doctor's doznaka must be extended, and RFZO's medical commission (lekarska komisija) will review your case. 5. **When recovered,** reactivate your business at APR and resume normal operations. --- ## Maternity leave and parental benefits Female paušalci are entitled to maternity leave (porodiljsko odsustvo) and childcare leave (odsustvo radi nege deteta), though the process differs from employment: ### Duration - **Maternity leave:** 3 months around birth (typically starting 28-45 days before expected delivery) - **Childcare leave:** Up to 9 additional months (total absence: approximately 12 months for the first child, 24 months for the second and subsequent children) ### Compensation During maternity and childcare leave, compensation is calculated based on the average income over the **18 months preceding the leave.** For paušalci, this is based on the paušalni prihod from the rešenje, not actual revenue. The compensation is paid by the local self-government (opština/grad), not RFZO. You must apply at your local Sekretarijat za socijalnu zaštitu (Social Protection Secretariat) with birth certificate, medical documentation, and APR dormancy registration. **Your social contribution obligations are covered during maternity/childcare leave** — you don't pay them out of pocket. However, the application process can take 1-3 months for the first payment, so plan your finances accordingly. ### Important notes - You must **freeze your business at APR** during maternity/childcare leave - Your social contribution obligations are **covered during the leave period** — you don't pay them out of pocket - The application process can be slow (1-3 months for first payment), so plan accordingly - Fathers can also use childcare leave (odsustvo radi nege deteta) after the initial 3-month maternity period --- ## Pension: what's accruing and how to verify ### How pension accrual works Your monthly PIO (pension and disability insurance) contribution builds your pension rights. As a paušalac, you accrue: - **Pension insurance staž (service years)** — each month of paid contributions counts as one month of pension service. 12 months of contributions = 1 year of service. - **Personal pension points** — these determine your actual pension amount. Points are calculated annually based on the ratio of your contribution base (paušalni prihod) to the national average wage. Since paušalci often have a lower assessed base than their actual income, their pension points accumulate more slowly than those of employed persons earning the same actual income. This means your eventual pension may be modest relative to your working income. ### Current pension eligibility To qualify for an old-age pension (starosna penzija) in Serbia, you need: - **Men:** 65 years of age + minimum 15 years of pension service - **Women:** Currently transitioning — reaches 65 years by 2032. Minimum 15 years of service. Early retirement is possible with 40 years of service (men) or 38 years (women), regardless of age. ### How to verify your pension records **Check your pension records at the PIO Fund at least once every 2-3 years.** Payment errors and administrative gaps can silently erode your service years. Finding and correcting a gap from 2 years ago is straightforward — correcting one from 15 years ago can require extensive documentation and months of back-and-forth. This is critical — and many paušalci neglect it until it's too late. The PIO Fund (Fond PIO) maintains a record of your contributions and service years. You should verify periodically that: 1. **All months are recorded.** Sometimes payments get misattributed (wrong BOP, as discussed in the tax payment article), and the PIO Fund shows gaps in your service. 2. **The contribution base is correct.** Your pension points depend on the recorded base, which should match your rešenje. 3. **Continuous service is properly recorded.** Gaps can reduce both total service years and the pension amount. **How to check:** - Visit your local PIO Fund branch (filijala Fonda PIO) with your ID - Request a listing of your pension service (listing staža) - Review it for gaps or discrepancies - If errors are found, file a correction request with supporting documentation (payment receipts, rešenja) --- ## Unemployment insurance: the contribution you'll probably never use ### What it covers Your unemployment insurance contribution (doprinos za nezaposlenost) — the smallest of the four at 0.75% — funds the National Employment Service (Nacionalna služba za zapošljavanje — NSZ). If you close your business and register as unemployed, you may be entitled to: - **Unemployment benefits** for a limited period (determined by years of prior contributions) - **Job placement assistance** through NSZ programs - **Retraining programs** ### Why most paušalci won't use it Unemployment benefits require you to be **registered as unemployed** at NSZ, actively seeking employment, and available for job placement. Most paušalci who close one business either open another, take employment, or leave Serbia — none of which qualify for unemployment benefits. The contribution is mandatory regardless. Think of it as the least impactful of your four payments — but one that provides a minimal safety net if you ever need to close your business and don't have immediate next steps. --- ## Gaps in protection: what contributions DON'T cover Despite paying approximately 45% of your assessed base in taxes and contributions, paušalci have notable coverage gaps compared to employed persons: **Paušalci have no paid vacation, no paid public holidays, and no severance protection.** These gaps are inherent to self-employed status. Plan accordingly with savings, private insurance, or voluntary additional pension contributions (dobrovoljno penzijsko osiguranje). **No paid vacation.** There is no mechanism for paušalci to receive compensation during time off. Employed persons get 20+ paid vacation days; paušalci get zero. **No paid public holidays.** Same issue. Employed persons are paid for non-working days; paušalci simply don't work and don't earn. **30-day sick leave gap.** As discussed above, the first month of illness is entirely self-funded. Employed persons receive sick leave compensation from day 1 (paid by their employer for the first 30 days, then by RFZO). **Lower pension base.** The paušalni prihod (assessed base) is typically much lower than actual income, meaning pension accrual is slower and the eventual pension amount may be insufficient. **No severance protection.** Employed persons receive severance pay upon termination. Paušalci closing their business receive nothing. These gaps are inherent to the self-employed status, not specific to Serbia. But they're worth understanding so you can plan accordingly — through savings, private insurance, or voluntary additional pension contributions (dobrovoljno penzijsko osiguranje, available through private pension funds). --- ## Key takeaways 1. **Health insurance is real and usable** — but verify your coverage is active by checking with RFZO or your dom zdravlja. Payment alone doesn't guarantee active status. 2. **Sick leave has a 30-day self-funded gap.** RFZO compensation only starts from day 31 (with exceptions for critical illness). A registered prekid suspends the contributions obligation under ZDOSO čl. 50 — with voluntary payment expressly allowed — but it does not close the gap. Plan an emergency fund accordingly. 3. **Maternity leave is available** with compensation based on your assessed base. You must freeze your business at APR during the leave. 4. **Check your pension records every 2-3 years** at the PIO Fund. Payment errors and administrative gaps can silently erode your service years. 5. **Your contributions buy a safety net, not a cushion.** The coverage is real but modest. Most paušalci supplement with private health insurance and personal savings. 6. **Unemployment insurance is mandatory but rarely used** by entrepreneurs. Consider it a minor cost of the system. # Serbia's Independence Test: All Nine Criteria for Contractors Source: https://preduzmi.com/articles/independence-test Published: 2026-03-16, updated 2026-08-21 > Understand all 9 criteria of Serbia's independence test for paušal entrepreneurs. Learn what triggers failure, the financial consequences, and practical strategies to strengthen your position. *Last updated: August 2026. Reflects current legislation under the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, consolidated through br. 6/2026), Articles 85 and 85a.* If you're a Serbian paušalac working primarily with one foreign client — and statistically, you probably are — the independence test (test samostalnosti) is the single biggest compliance risk you face. Fail it, and income from that client is reclassified from "self-employment income", where tax and contributions are charged on your assessed paušal base, to "other income", where they are charged on the gross the client pays: 20% tax (ZPDG čl. 86 st. 1) plus 24% PIO (ZDOSO čl. 44 st. 1 t. 1). What changes is the base, not only the rate. This guide breaks down all 9 criteria, explains exactly how the test works, walks through the scenarios that most commonly trigger failure, and provides concrete strategies to strengthen your position. --- ## What is the independence test? The test samostalnosti was introduced in 2020 to combat what Serbian legislators call "fictitious entrepreneurship" — situations where a person registers as a paušalac but functions, in practice, as a disguised employee of a single company. The concern is that companies (especially foreign ones) use Serbian preduzetnici as cheap labor without paying employer social contributions. The test is codified in **Article 85, paragraph 1, point 17** and **Article 85a** of the Zakon o porezu na dohodak građana. It applies to the **relationship between a preduzetnik and each individual client** — you can pass the test with one client and fail it with another. ### The core rule The test examines **9 criteria**. If **5 or more** criteria indicate dependence in your relationship with a specific client, the Tax Authority can reclassify the income from that client as "other income" (drugi prihodi) rather than self-employment income. **Failing 5 or more of the 9 criteria with a single client triggers income reclassification.** The affected income is then charged on the gross that client pays — 20% tax (ZPDG čl. 86 st. 1) plus 24% PIO (ZDOSO čl. 44 st. 1 t. 1) — rather than on your assessed paušal base. If that client represents most of your revenue, the financial impact is severe. This reclassification doesn't mean you lose paušal status for all your income — only the income from the specific client relationship that failed the test. But if that client represents 80-90% of your revenue (as is common for IT freelancers), the practical impact is devastating. --- ## The 9 criteria explained For each criterion, the test asks whether the relationship looks more like employment or more like independent contracting. Here's what each one means in practice: ### Criterion 1: Number of clients **Fails if:** The preduzetnik earned more than 70% of their total revenue from a single client in the past 12 months. **Passes if:** Revenue is distributed across multiple clients, with no single client exceeding 70%. This is the most commonly failed criterion and the hardest to fix quickly. If you have one long-term foreign client paying you €4,000/month and a sporadic local client paying €500 twice a year, you're failing this criterion by a wide margin. **Practical strategy:** Actively seek additional clients — even small projects. A few smaller contracts that generate 30%+ of revenue from sources other than your primary client will flip this criterion. Some paušalci take on consulting, training, or code-review work specifically to diversify. ### Criterion 2: Working hours **Fails if:** The client determines your working hours (e.g., "you must be online 9-5 CET"). **Passes if:** You set your own schedule and are free to work when you choose. The key question is control, not synchronization. If you happen to work 9-5 because that's when you're productive, that's fine. If the client's contract says "consultant must be available 9:00–17:00 CET, Monday through Friday" — that reads like an employment schedule. **Practical strategy:** Ensure your contract specifies deliverables and deadlines, not working hours. Replace language like "working hours: 9-5" with "deliverables will be completed by agreed deadlines." If you attend daily standups, frame them as coordination meetings, not mandatory attendance requirements. ### Criterion 3: Vacation and leave **Fails if:** The client approves or controls when you take time off. **Passes if:** You independently decide when to take breaks, vacations, or time off, simply informing the client as a courtesy. If you submit PTO requests through the client's HR system, that's a red flag. If you send an email saying "I'll be unavailable August 10-24, deliverables X and Y will be completed before I leave" — that's independent scheduling. **Practical strategy:** Never use the client's internal leave management system. Communicate time off as notifications, not requests. Your contract should state that the contractor determines their own schedule. ### Criterion 4: Workplace **Fails if:** The client provides the workspace (you work at their office or are required to use their co-working space). **Passes if:** You work from your own location — home, your own rented office, a co-working space you pay for yourself. Working from a client's office regularly is a strong indicator of employment. Occasional on-site visits for meetings or workshops are fine and expected. **Practical strategy:** Work from your own space. If you visit the client's office, document it as project-related travel, not your regular workplace. Your contract should specify that services are performed at the contractor's own premises. ### Criterion 5: Training and professional development **Fails if:** The client organizes and pays for your training, skill development, or certifications. **Passes if:** You manage and fund your own professional development. Attending the client's internal "lunch and learn" sessions is borderline. Being enrolled in their onboarding program, mandatory compliance training, or sponsored certification courses looks like employment. **Practical strategy:** Pay for your own courses, conferences, and certifications. If the client offers training, consider whether attending is genuinely optional and relevant to the specific project, or whether it's part of their employee development program. ### Criterion 6: Equipment and tools **Fails if:** The client provides your primary work equipment (laptop, software licenses, specialized tools). **Passes if:** You use your own equipment and tools. This is common in IT: the client ships you a company laptop with pre-configured access. Convenient? Yes. Independence test problem? Also yes. **Using your own equipment is one of the easiest criteria to pass.** If the client requires a managed device for security reasons, document why (e.g., "infosec policy requires VPN from managed devices") and ensure your contract frames this as a project requirement, not equipment provision. **Practical strategy:** Use your own hardware. If the client requires specific software (access to their VPN, their Jira instance, their Slack), that's normal project tooling. But your primary work machine should be yours. If you must use a client-provided device for security reasons, document why (e.g., "client's infosec policy requires VPN access from managed devices for accessing production systems") and ensure your contract frames this as a project requirement, not equipment provision. ### Criterion 7: Exclusivity **Fails if:** The client contractually prohibits you from working with other clients (non-compete or exclusivity clause during the engagement). **Passes if:** You are free to take on other work simultaneously. Review your contract carefully. Some clients include non-compete clauses by default in their contractor agreements. Even if they don't enforce it, the clause itself can fail this criterion. **Practical strategy:** Negotiate removal of exclusivity and non-compete clauses from your contract. Accept reasonable confidentiality (NDA) and non-solicitation clauses instead — these don't indicate employment. If the client insists on exclusivity, this is a significant test risk. ### Criterion 8: Permanence of relationship **Fails if:** The engagement has no defined end date or project scope — it's an open-ended, indefinite arrangement. **Passes if:** The engagement is project-based with a defined scope, deliverables, and timeline (even if renewed periodically). A contract that says "ongoing services until terminated by either party" looks like employment. A contract that says "development of Module X, estimated 6 months, with option to extend for Module Y" looks like independent project work. **Structure your contracts as project-based agreements** with defined scopes and timeframes, even if you intend to continue working with the client long-term. When a project ends, sign a new contract for the next phase rather than rolling the same contract forward indefinitely. **Practical strategy:** Structure your contracts as **project-based agreements** with defined scopes and timeframes, even if you intend to continue working with the client long-term. When a project ends, sign a new contract for the next phase rather than rolling the same contract forward indefinitely. Each contract should have a clear scope of work and deliverables. ### Criterion 9: Risk bearing **Fails if:** The preduzetnik bears no financial risk — they get paid a fixed amount regardless of outcomes, with no liability for defects or delays. **Passes if:** The preduzetnik bears business risk — responsibility for quality, potential rework at own cost, warranties on deliverables, liability for deadline failures. A pure time-and-materials arrangement where you bill hours and the client accepts whatever you produce looks more like employment. A fixed-price project where you bear the risk of underestimating effort, with a warranty period for bug fixes, looks like independent contracting. **Practical strategy:** Include warranty or defect-correction clauses in your contract. Consider fixed-price projects (or at least fixed-price milestones) rather than pure hourly billing. Your contract should include provisions for your liability in case of non-delivery or quality issues. --- ## How the test is applied The Tax Authority (Poreska uprava) doesn't proactively test every paušalac. The test is typically triggered by: 1. **Automated risk scoring** — the Tax Authority's systems flag entrepreneurs with high revenue concentration from a single source 2. **Tax inspections** — during a routine or targeted inspection, the inspector evaluates the independence criteria 3. **Cross-border reporting** — some countries report payments to Serbian residents, and high payments from a single foreign entity attract attention When triggered, the Tax Authority examines the actual relationship — not just the contract text. They may request: your contract(s), invoices, communication records, evidence of work arrangements, and bank statements. They assess each of the 9 criteria and determine whether 5+ indicate dependence. ### The assessment is per client If you have three clients — one large (70% of revenue) and two small (15% each) — the test is applied separately to each client relationship. You might fail the test with the large client (criterion 1 automatically fails, plus perhaps 4 others) while passing it with the small ones. Only the income from the failing relationship gets reclassified. --- ## What happens if you fail **Reclassification changes the base, not just the rate.** The paušal charge is computed on your assessed base and stays flat; reclassified income is charged on the gross the client pays — 20% tax (ZPDG čl. 86 st. 1) plus 24% PIO (ZDOSO čl. 44 st. 1 t. 1), which is 44% of gross on the two components that always apply. Retroactive assessment for prior periods is possible on top. If 5 or more criteria indicate dependence with a specific client: 1. **Income from that client is reclassified** as "other income" (drugi prihodi) under Article 85, paragraph 1, point 17. 2. **20% tax on the gross amount** — ZPDG čl. 86 st. 1. There are no *normirani troškovi* to subtract here: čl. 85 st. 5 t. 1 carves point 17 out of the general 20% deduction, so the taxable amount *"čini bruto prihod obveznika poreza"* — the gross the client paid, with nothing deducted from it. 3. **24% PIO on the same gross base** — ZDOSO čl. 44 st. 1 t. 1, with čl. 28 st. 1 making the taxable income the contribution base. (The 25.5% figure that circulates widely is the 2019 rate; the PIO rate has been 24% since 1 January 2022.) 4. **Health contribution of 10.3% — only where the person is not already health-insured on another basis.** A registered paušalac is: you pay the health contribution monthly on your paušal base. So for an active paušalac it does not arise a second time on the reclassified income. That is a derivation from your insurance status, not a rule written for the independence test — check it for your own case, especially if the paušalac has been closed or paused. 5. **The tax is withheld at source by the nalogodavac** — ZPDG čl. 85 st. 15–17. Where the payer is a Serbian entity, it calculates, withholds, and pays the tax with each payment. A foreign client is not a domestic withholding agent, so the obligation falls on you by self-assessment. 6. **The client also faces liability.** If the client is a Serbian entity, they owe employer contributions. For foreign clients, enforcement is limited — but the burden falls entirely on the preduzetnik. 7. **Retroactive assessment is possible.** The Tax Authority can reclassify income for the current and previous periods within the statute of limitations. Adding the two components that always apply gives 20% + 24% = **44% of the gross** the client pays. That is arithmetic on the rates above, not a published effective rate — and where the health contribution does apply, add 10.3% to it. The base is what makes it bite: the paušal charge is computed on your assessed base and does not move with revenue, while this is computed on every dinar the client pays. --- ## The IT freelancer problem The independence test disproportionately affects IT professionals because of a common working pattern: one long-term foreign client, daily standups, the client's Jira and Slack, sometimes a client-provided laptop, and an indefinite engagement that has been rolling for 2+ years. If this sounds like you, here's a realistic self-assessment: | Criterion | Typical IT freelancer status | Risk | |-----------|------------------------------|------| | 1. Revenue concentration | >70% from one client | Fails | | 2. Working hours | Client sets sprint schedules | Borderline | | 3. Leave approval | Uses client's PTO system | Fails | | 4. Workplace | Works from home (own space) | Passes | | 5. Training | Client's onboarding program | Fails | | 6. Equipment | Own laptop, client's software | Borderline | | 7. Exclusivity | No formal exclusivity clause | Passes | | 8. Permanence | Open-ended engagement | Fails | | 9. Risk bearing | Hourly billing, no warranty | Fails | In this scenario, 5-6 criteria fail. The test would not go well. ### How to improve this position You don't need to pass all 9 — just keep failures below 5. The most actionable improvements: 1. **Get a second client** (fixes criterion 1 if you can shift 30%+ of revenue) 2. **Restructure your contract** as a project-based engagement with defined scope and timeline (fixes criterion 8) 3. **Add warranty/liability clauses** (fixes criterion 9) 4. **Stop using the client's PTO system** — notify about absences instead (fixes criterion 3) 5. **Decline client-organized training** where possible (fixes criterion 5) Items 2-5 can often be implemented by renegotiating your contract — something many clients are willing to do if you explain the legal context. --- ## Key takeaways 1. **9 criteria, fail on 5+ = reclassification.** The test evaluates your relationship with each client independently. 2. **Revenue concentration is the #1 risk factor.** More than 70% from one client automatically fails criterion 1 and signals risk on other criteria. 3. **Contracts matter enormously.** Project-based scope, no exclusivity, no working-hour requirements, warranty clauses — these contractual elements directly address multiple criteria. 4. **The test looks at substance, not just form.** A contract that says "independent contractor" but describes an employment relationship won't pass. 5. **Diversifying clients is the single most effective protection.** Even small additional clients that shift revenue distribution below 70% make a significant difference. 6. **When in doubt, consult a tax advisor.** The independence test has nuances (especially for foreign clients where enforcement mechanisms differ), and a professional assessment of your specific situation is worth the investment. # KPO Knjiga Demystified: How to Track Revenue Correctly Source: https://preduzmi.com/articles/kpo-book Published: 2026-03-16, updated 2026-08-21 > Everything you need to know about Serbia's KPO book for paušal entrepreneurs: what goes in, what doesn't, foreign currency conversion, paper vs electronic format, and the 7 most common mistakes. *Last updated: August 2026. Reflects current requirements under the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, consolidated through br. 6/2026) and the [Pravilnik o poslovnim knjigama i iskazivanju finansijskog rezultata po sistemu prostog knjigovodstva](https://www.paragraf.rs/propisi/pravilnik-o-poslovnim-knjigama-finansijski-rezultat-po-sistemu-prostog-knjigovodstva.html) ("Sl. glasnik RS", br. 140/2004 i 44/2018 – dr. zakon).* Every Serbian paušalac must maintain a KPO knjiga — the Book of Realized Turnover. It's your only mandatory bookkeeping obligation and the primary document the Tax Authority uses to verify your revenue. Despite being a simple ledger, the KPO generates a surprising amount of confusion. Paušalci routinely record things that don't belong, omit things that do, use wrong exchange rates, and sometimes don't maintain one at all. This guide covers everything you need to know: what the KPO is, what goes into it (and what absolutely doesn't), how to handle foreign-currency invoices, paper vs electronic format, and the seven most common errors that draw attention from the Poreska uprava. --- ## What is the KPO knjiga? The Knjiga o ostvarenom prometu (KPO) — literally "Book of Realized Turnover" — is a chronological register of every invoice you issue. Think of it as a revenue log. You record each invoice as you issue it, with basic details: date, description, amount. That's it. There is no expense tracking, no balance sheet, no profit-and-loss statement. Paušalci are specifically exempt from full bookkeeping — the KPO is the simplified alternative. The legal basis is **ZPDG čl. 43 st. 4** — *"Preduzetnici paušalci dužni su da vode samo poslovnu knjigu o ostvarenom prometu"* — together with the **Pravilnik o poslovnim knjigama i iskazivanju finansijskog rezultata po sistemu prostog knjigovodstva** ("Sl. glasnik RS", br. 140/2004 i 44/2018 – dr. zakon). Its čl. 3 st. 3 prescribes the KPO form; its čl. 7 prescribes what goes in it. There is no separate KPO rulebook: the KPO is one of the forms in the simple-bookkeeping rulebook, printed as an annex to it. --- ## What goes into the KPO The form has **five columns**, prescribed by čl. 7 of the Pravilnik: **Column 1 — Redni broj (sequential number)** A running count from the start of the year: 1, 2, 3, and so on. It resets to 1 on January 1, or on the day you start trading if that falls later in the year. The rulebook adds a detail most guides omit: the same number must be written in the top right-hand corner of the underlying document — the invoice the entry is based on. **Column 2 — Datum i opis knjiženja (date and description of the entry)** Date and description share a single column. The description identifies the transaction: "Web development services for Company X, Invoice #2025-047." No elaborate detail is needed. For the date, use the **datum prometa** — the date the service was delivered or the goods supplied. For a service delivered across a period (a monthly retainer, say), that is normally the last day of the period. This date determines which calendar year and which rolling 12-month window the revenue falls into. **Columns 3 and 4 — Prihod od proizvoda / prihod od usluga** The amount, split by what earned it: revenue from products sold in column 3, revenue from services performed in column 4. A paušalac who sells only services fills column 4 and leaves column 3 empty. Amounts are in dinars; a foreign-currency invoice is converted first (see below). **Column 5 — Ukupno (total)** The sum of columns 3 and 4 for that row. That's the entire structure. Five columns. One row per invoice. **The entry does not wait for payment.** In a clarification published on 29 January 2026, the Poreska uprava stated that turnover in a tax period consists of income earned in that period — the period in which the goods or services were supplied — where the transaction has been documented by an invoice and recorded in the KPO, *"nezavisno od okolnosti da li je i kada realizovana naplata potraživanja po tom osnovu"*: regardless of whether and when the receivable was collected. You record the invoice when you issue it. An unpaid invoice still counts, and a client who pays in January does not move a December entry into the new year. --- ## What does NOT go into the KPO This is where most mistakes happen. The KPO records **only revenue from your business activity.** The following items must never appear in it: **Bank transfers between your own accounts.** Moving money from your business account to your personal account is not revenue. Recording it would double-count your income. **Expenses and costs.** You bought a laptop for work? A plane ticket to visit a client? These are not revenue. Paušalci don't track expenses in any official capacity — the paušal system assumes a standardized expense deduction built into the tax formula. **Loan proceeds.** If you received a business loan, that's not turnover. Don't record it. **Refunds or reversed transactions.** If a client overpaid and you returned the excess, you need to record a storno (reversal) entry, not add the refund as a negative expense. **Interest income.** Bank interest earned on your business account balance is not business turnover from your registered activity. **Private income.** Salary from an employer (if you're running paušal as a side business), rental income, investment returns — none of these belong in the KPO. The golden rule: **if it's not an invoice you issued for your registered business activity, it doesn't go in the KPO.** --- ## Paper vs electronic KPO You have two options, and the rulebook permits both. ### Paper KPO Purchase a physical KPO book from a bookstore or stationery shop (they're sold pre-formatted). Entries must be made in ink. Corrections require crossing out the error with a single line (so the original remains readable), writing the correct entry, and adding a note with the date of correction. No white-out, no erasing. ### Electronic KPO (Elektronska knjiga) Electronic keeping is **explicitly permitted**, and has been since the rulebook took effect — not since 2020. Čl. 4 st. 1 allows business books to be kept in loose leaves, bound, or *"prenete na neki od medijuma automatske ili mikrografske obrade podataka, tako da se po potrebi mogu odštampati ili prikazati na ekranu"*: transferred to a medium of automatic data processing, so that they can be printed **or displayed on screen** when needed. Nothing in the rulebook requires routine printing. So a spreadsheet, a dedicated app, or any digital format that preserves the prescribed structure — the five columns above — satisfies the rule. What you must be able to do is produce the book when an inspector asks, on screen or on paper. A format with an audit trail (a spreadsheet with version history, or a bookkeeping tool) is easier to defend than a freely editable document. ### Certification (overavanje): what the rulebook says, and what is unsettled Čl. 4 st. 3 of the Pravilnik still reads that the books under čl. 3 st. 1 and st. 3 — the latter being the KPO — *"overavaju se kod nadležnog poreskog organa pre početka knjiženja"*: they are certified by the competent tax authority **before bookkeeping begins**. That is a before-you-start rule, not an annual one. The rulebook prescribes no yearly re-certification, and on its face the sentence does not distinguish a paper book from an electronic one. Whether the Poreska uprava still performs this certification in practice is **unsettled**. Published guidance splits several ways — some sources describe stamping as routine, others report that branches no longer do it at all — and we have found no primary source that settles current practice either way. Do not assume an annual obligation, and do not assume the requirement has quietly lapsed. If you intend to keep a paper book, ask your local branch what it expects before you write the first line in it. --- ## Foreign-currency invoices: the conversion rule If you invoice in EUR, USD, or any other currency, the amount goes into the KPO in dinars. The **type** of rate is prescribed: for bookkeeping and statistics the law requires the NBS **official middle rate**, *zvanični srednji kurs* (Zakon o deviznom poslovanju čl. 41 st. 2). Which day's middle rate applies is not prescribed for a non-VAT paušalac — the KPO rulebook lays down no conversion rule at all — so converting at the **datum prometa** is settled practice rather than a statutory command. Apply one convention to every invoice and keep it consistent year to year; this guide uses the datum prometa throughout. **Example:** You issue an invoice for €2,500 with a service date of October 15, 2025. The NBS middle rate on October 15 is 117.35 RSD/EUR. Your KPO entry records 293,375 RSD (2,500 × 117.35). A few important points: - Use the **middle rate** (srednji kurs), not the buying or selling rate. - Having chosen the **datum prometa** convention, apply it consistently: not the date the client paid, and never the rate your bank applied during conversion — that last one is the part the law does settle. - The difference between the NBS middle rate and the rate your bank actually applies when converting the incoming payment is called a kursna razlika (exchange rate difference). This difference is irrelevant for KPO purposes. - If the NBS didn't publish a rate on that specific date (weekend or holiday), use the rate from the last business day before it. --- ## Storno entries: correcting or canceling invoices If you need to cancel or correct a previously recorded invoice, you make a **storno** entry in the KPO. This is a new line with the next sequential number, referencing the original entry, with a negative amount. **Example:** - Entry #23: Invoice #2025-023, October 10, Web development for Client X, 250,000 RSD - Entry #24: **STORNO of Entry #23**, October 15, Cancellation of Invoice #2025-023, **-250,000 RSD** If you're correcting the amount rather than canceling entirely: - Entry #24: STORNO of Entry #23, -250,000 RSD - Entry #25: Corrected Invoice #2025-023-R, 230,000 RSD The running total in your KPO will reflect the net correct amount. Never go back and modify or delete an existing entry — always add a new storno line. --- ## The 7 most common KPO mistakes Based on forum discussions, Tax Authority inspection reports, and questions from the paušalci community, these are the errors that cause the most problems: ### Mistake 1: Recording expenses The KPO is income-only. No office rent, no equipment purchases, no travel costs, no subscriptions. Paušalci occasionally start recording expenses "just in case" or because they think it will help at tax time. It won't — and it confuses your revenue total. ### Mistake 2: Recording bank-to-bank transfers Transferring 200,000 RSD from your business account to your personal account is not revenue. It's your own money moving between your own accounts. Recording it inflates your apparent turnover and can push you closer to (or over) the revenue limits. ### Mistake 3: Using the wrong exchange rate Three common sub-errors here: - Using the bank's conversion rate instead of the NBS middle rate - Using the rate on the payment date instead of the service date - Using a rate from a random currency converter website instead of the official NBS rate ### Mistake 4: Not converting foreign invoices at all Some paušalci record EUR invoices as-is: "€3,000" in the amount column. The KPO must be in RSD. Every foreign-currency amount must be converted. ### Mistake 5: Breaking chronological order KPO entries must be in strict chronological order by service date. If you issue Invoice #50 on March 15 and Invoice #51 on March 10 (for a service delivered earlier), the KPO must record Invoice #51 first (March 10) and Invoice #50 second (March 15). ### Mistake 6: Not maintaining the KPO at all Some paušalci — particularly those with only a few invoices per year — simply don't keep a KPO, assuming it's optional or that their bank statements are sufficient. The KPO is **mandatory**. ### Mistake 7: Guessing about overavanje Two guesses circulate, and both are guesses: that a paper book must be re-certified by the tax office every January, and that certification stopped being a thing years ago. The rulebook says certification happens **before bookkeeping begins** (čl. 4 st. 3), says nothing about repeating it annually, and current practice is not documented in any source we can verify. Ask your branch rather than inferring, and keep whatever they tell you together with the book. --- ## KPO and tax inspections During a poreska kontrola (tax inspection), the inspector will typically request: 1. Your KPO knjiga (paper or electronic printout) 2. Copies of all invoices referenced in the KPO 3. Your bank statements for the same period The inspector cross-references these three sources. Invoices should match KPO entries (same dates, same amounts after conversion). Bank statement deposits should correspond to invoiced amounts (allowing for exchange rate differences and payment timing). The best defense during an inspection is a clean, chronological KPO that matches your invoices exactly. --- ## Key takeaways 1. **KPO records only income** from your business activity. Never expenses, transfers, loans, or personal income. 2. **Five columns** (Pravilnik čl. 7): sequential number; date and description of the entry; revenue from products; revenue from services; total. Not four. 3. **Foreign invoices must be converted** to RSD at the NBS official middle rate — the rate type the law prescribes (ZDP čl. 41 st. 2). Which day's rate applies is not prescribed for a non-VAT paušalac; this guide uses the service date, and consistency matters more than the choice. 4. **Electronic keeping is explicitly allowed** (Pravilnik čl. 4 st. 1) and no routine printing is required — the book must simply be producible on screen or on paper when asked. Certification under čl. 4 st. 3 happens *before bookkeeping begins*, not annually, and whether the tax office still performs it is unsettled. 5. **Chronological order is mandatory.** Sort by service date, not invoice number or issue date. 6. **Never modify existing entries.** Use storno (reversal) lines for corrections and cancellations. 7. **The KPO total is your official revenue** for limit calculations. Keep it accurate and you'll never be surprised by a Tax Authority inquiry. # 6 Million vs 8 Million: The Complete Guide to Serbian Paušal Revenue Limits Source: https://preduzmi.com/articles/revenue-limits Published: 2026-03-16, updated 2026-08-21 > Understand the two revenue thresholds for Serbian paušal entrepreneurs: the 6M calendar-year limit and the 8M rolling 12-month PDV limit. Learn how each is calculated and what happens if you exceed them. *Last updated: August 2026. This guide reflects current legislation including the [Zakon o porezu na dohodak građana](https://www.paragraf.rs/propisi/zakon-o-porezu-na-dohodak-gradjana.html) ("Sl. glasnik RS", br. 24/2001, consolidated through br. 6/2026) and the [Zakon o PDV](https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2004/84/3/reg) ("Sl. glasnik RS", br. 84/2004, with amendments).* If you're a Serbian paušalac — or thinking about becoming one — there are two numbers you should know well: **6,000,000** and **8,000,000**. These are the revenue thresholds that determine whether you keep your lump-sum tax status, and they work in completely different ways. Confusing them is the single most common mistake paušalci make, and the consequences range from losing your favorable tax treatment to owing retroactive VAT on months of revenue. This guide explains both limits in plain language, shows exactly how each one is calculated, walks through real scenarios, and tells you what happens if you cross either threshold. --- ## The short version Serbia's lump-sum taxation system (paušalno oporezivanje) has two independent revenue caps governed by two separate laws: **Limit 1 — 6,000,000 RSD per calendar year.** If your total revenue from January 1 to December 31 exceeds this amount, you lose paušal status and must switch to full bookkeeping (knjigaš) starting from the next applicable period. This is governed by Article 40 of the Income Tax Law. **Limit 2 — 8,000,000 RSD in any rolling 12-month period.** If your total revenue in *any* consecutive 365-day window exceeds this amount, you must register for PDV (VAT). VAT registration automatically ends your paušal status. This is governed by Article 33 of the VAT Law. These are not the same limit viewed two ways. They are separate legal mechanisms with different calculation windows, different consequences, and different dates on which they apply. --- ## Limit 1: The 6-million calendar year threshold ### What it means The Zakon o porezu na dohodak građana (Income Tax Law), Article 40, paragraph 2, point 4, states that lump-sum taxation cannot be recognized for a taxpayer whose total turnover in the **preceding year** exceeds 6,000,000 RSD (approximately €51,000 at current exchange rates). This limit is measured on a strict calendar-year basis: January 1 through December 31. ### How revenue is counted This is where most confusion starts. Revenue counts based on the **date of service delivery or invoice issuance** (datum prometa / datum izdavanja fakture), **not** the date payment lands in your bank account. Here's what that means in practice: - You perform consulting work in December 2025 and issue an invoice dated December 28, 2025 - Your client pays you on January 15, 2026 - That revenue counts toward your **2025** total, not 2026 The official record is your KPO knjiga (Book of Realized Turnover), where you record each invoice chronologically by service date. The Tax Authority will use your KPO entries — not your bank statements — to verify compliance. ### Foreign currency invoices If you invoice in EUR, USD, or any other foreign currency, what counts toward the 6-million limit is the dinar amount converted at the **NBS official middle rate** (zvanični srednji kurs Narodne banke Srbije). The *type* of rate is prescribed: ZDP čl. 41 st. 2 — *"Za potrebe knjigovodstva i statistike primenjuje se zvanični srednji kurs dinara."* Applying the buying rate, the selling rate or the rate your bank used is a prekršaj, and for a preduzetnik it carries 150,000 to 500,000 RSD (ZDP čl. 61 t. 37). **Which date's rate applies is prescribed nowhere for a paušalac outside the VAT system.** ZPDV čl. 22 fixes the conversion date for the VAT base and binds VAT payers; the Zakon o računovodstvu defines *preduzetnici* as those keeping double-entry books (čl. 2 t. 3), which a paušalac does not; the KPO pravilnik prescribes the columns and no conversion rule at all. The invoice date — or the supply date where the two differ — is settled practice, not a rule. Pick one basis and apply it to every invoice. The full argument is in [foreign currency inflows](/articles/foreign-currency-inflows). For example: you issue an invoice for €3,000 on March 15, and the NBS middle rate that day is 117.20 RSD/EUR. Your KPO entry — and your limit calculation — records 351,600 RSD. The actual amount your bank credits after conversion (which uses the bank's own, less favorable rate) is irrelevant for limit purposes. ### What happens if you exceed 6 million The consequences depend on *when* in the year you cross the threshold: **If you exceed 6M in the first half of the year (January–June):** The Tax Authority issues a decision requiring you to switch to full bookkeeping (knjigaš) starting from **July 1** of that year. **If you exceed 6M in the second half (July–December):** The obligation to switch starts **January 1 of the following year.** In both cases, you can apply to return to paušal status if your revenue drops below 6 million in a subsequent calendar year. The application must be filed by **October 31** of the year before you want to switch back. The 6-million limit does NOT trigger VAT. Exceeding 6 million forces you into bookkeeping, but it does not by itself require VAT registration. You become a knjigaš who is still outside the VAT system — unless you also breach the 8-million rolling threshold. --- ## Limit 2: The 8-million rolling 12-month threshold ### What it means The Zakon o porezu na dodatu vrednost (VAT Law), Article 33, defines a "mali obveznik" (small taxpayer) as one whose total turnover in the **previous 12 months** does not exceed 8,000,000 RSD (approximately €68,000). The moment your rolling 12-month revenue crosses 8 million, you are no longer a "small taxpayer" and must register for PDV (VAT). ### The rolling window is the key difference Unlike the 6-million limit, the 8-million threshold doesn't care about calendar years. It looks at a **continuous 365-day window ending today.** On any given day, the question is: "What was my total revenue over the preceding 365 days?" If the answer exceeds 8 million, the VAT obligation is triggered — regardless of how that revenue falls across calendar years. This creates a scenario that catches many paušalci off guard: **Example:** You earn 5,500,000 RSD from July to December 2025, then 4,000,000 RSD from January to June 2026. Neither calendar year exceeds 6 million. But the rolling 12-month total from July 2025 through June 2026 is 9,500,000 RSD — well over the 8-million PDV threshold. ### The foreign-services exception For paušalci who provide services exclusively to foreign clients, there's an important nuance: that revenue generally does not count toward the 8-million threshold. Two provisions produce the result. **ZPDV čl. 33 st. 6** limits *ukupan promet* for the threshold to the supplies in čl. 28 st. 1 t. 1) and t. 2) — those taxed in Serbia and those exempt with the right to deduct — and leaves out t. 3), a supply performed abroad. **ZPDV čl. 12 st. 4** puts the place of supply of a service to a business client in the country where that client is established. If you're a software developer in Belgrade building an app for a German company, that service is supplied in Germany, not in Serbia, so it falls into t. 3) and drops out of the count. Such revenue enters your 6-million paušal calculation but generally does **not** count toward the 8-million PDV threshold. Čl. 12 sets special rules for particular categories of service, so check an unusual one rather than assuming. This distinction matters enormously for IT freelancers — but it's also genuinely complex. If you're in this situation, confirm with a Serbian tax advisor before assuming the exemption applies to your specific services. ### What happens if you exceed 8 million The consequences are more severe and more immediate than the 6-million breach: 1. **VAT registration becomes mandatory from the next day.** You must file the EPPDV registration form within **5 days** — calendar days, not working days (ZPDV čl. 38 st. 1). 2. **Paušal status is terminated immediately.** Unlike the 6-million threshold (which has H1/H2 transitional periods), the 8-million breach means instant loss of lump-sum taxation. 3. **You owe VAT retroactively** from the date the threshold was exceeded, but **without the right to deduct input VAT** for that retroactive period — a severe penalty. 4. If you fail to self-register, the Tax Authority can perform compulsory registration and assess additional penalties. This is why the 8-million limit is often considered more dangerous than the 6-million limit. The 6-million breach is inconvenient (you switch to bookkeeping); the 8-million breach is financially punishing. --- ## How the two limits interact — four scenarios To make this concrete, here are four scenarios showing how the limits interact: ### Scenario A: Safe on both You earn 450,000 RSD per month consistently throughout 2025. Your calendar-year total is 5,400,000 (under 6M). Your rolling 12-month total is also 5,400,000 at any point (under 8M). You're safe on both counts. ### Scenario B: Exceed calendar year, safe on rolling You receive several large projects and earn 6,500,000 RSD between January and December 2025, but with most revenue concentrated in the summer. If your rolling 12-month total never exceeds 8M on any given day, you lose paušal status (switch to bookkeeping in H1 or H2 depending on timing) but don't need to register for VAT. ### Scenario C: Safe on calendar year, exceed rolling 12 months You earn 5,900,000 RSD in calendar year 2025 (under 6M) and 5,900,000 in 2026 (also under 6M). But from August 2025 to July 2026, your 12-month total is 8,200,000. You must register for VAT, which also terminates your paušal status — even though you never exceeded 6M in any single calendar year. This is the trap scenario. It's entirely possible to breach the 8-million rolling limit while staying under 6 million in every calendar year. ### Scenario D: Exceed both You earn 7,000,000 RSD in calendar year 2025. You've exceeded the 6-million paušal limit (switch to bookkeeping). If at any point your rolling 12-month total also exceeds 8 million, you must also register for VAT. Both consequences apply independently. --- ## How to track your limits effectively Given the different calculation windows, tracking both limits requires slightly different approaches: **For the 6-million calendar year limit:** Sum all your invoice amounts (converted to RSD at the NBS middle rate — the rate type is prescribed, the date is whichever convention you apply consistently) with service dates in the current year. Reset on January 1. **For the 8-million rolling 12-month limit:** At any point, sum all invoice amounts with service dates in the preceding 365 days. This number changes every day as old invoices roll out of the window and new ones enter. Doing this manually in a spreadsheet is error-prone — you need to recalculate the rolling total after every invoice and remember to use the correct exchange rates. ### Warning thresholds Don't wait until you're at 5,900,000 to start worrying. Practical warning levels: **6-million calendar year:** - **Yellow zone (4,000,000–5,000,000):** Start planning. Can you defer some invoicing to next year? - **Orange zone (5,000,000–5,500,000):** Active risk. Every new invoice matters. - **Red zone (5,500,000+):** Consider engaging an accountant to prepare for potential knjigaš transition. **8-million rolling 12 months:** - **Yellow zone (6,000,000–7,000,000):** Monitor monthly. - **Orange zone (7,000,000–7,500,000):** Monitor weekly. - **Red zone (7,500,000+):** Consider voluntary VAT registration (to control timing) or restructuring your business. --- ## Common misconceptions **"The limit is based on money received in my bank account."** No. It's based on invoices issued / services delivered. A December invoice paid in January counts in December. **"I can issue invoices in EUR and only the dinars I actually receive count."** No. The whole invoiced amount counts, converted at the NBS official middle rate (ZDP čl. 41 st. 2). Which date's rate you use is not prescribed for a paušalac outside the VAT system — the invoice date, or the supply date where the two differ, applied consistently, is settled practice. **"If I work only for foreign clients, the 8-million limit doesn't apply to me."** Partially true — if the place of supply is abroad, those services may not count toward the 8M PDV threshold. But they *always* count toward the 6M paušal threshold. **"If I exceed 6 million, I automatically go into PDV."** No. Exceeding 6M triggers bookkeeping obligations. PDV registration is triggered only by exceeding 8M (rolling) or by voluntary registration. **"I can just split invoices across years to stay under the limit."** Risky. The Tax Authority looks at the actual service delivery date (datum prometa), not when you choose to issue the invoice. Artificially delaying invoices for services already rendered can constitute tax evasion. --- ## Key takeaways 1. **Two separate limits, two separate laws, two separate calculation windows.** Don't conflate them. 2. **6M is calendar year, 6M is about bookkeeping.** Exceed it and you become a knjigaš. Inconvenient but manageable. 3. **8M is rolling 12 months, 8M is about VAT.** Exceed it and you owe retroactive VAT without input deductions. Financially severe. 4. **Both count from invoice/service date, not payment date.** Your KPO knjiga is the source of truth. 5. **Foreign-currency invoices convert at the NBS official middle rate** (ZDP čl. 41 st. 2). The rate *date* is not prescribed for a paušalac outside the VAT system — use the invoice date or the supply date, and use the same one every time. 6. **Track both limits continuously.** The rolling 12-month calculation changes daily and can sneak up on you even when calendar-year revenue looks safe. 7. **When in doubt, consult a Serbian tax advisor.** This guide explains the general rules, but individual situations — especially around the foreign-services PDV exemption — require professional assessment. # How to Pay Your Paušal Taxes: 4 Payments, 4 Accounts, and Reference Numbers Source: https://preduzmi.com/articles/tax-payments Published: 2026-03-16, updated 2026-08-21 > Step-by-step guide to making monthly paušal tax payments in Serbia: treasury accounts, BOP reference numbers, payment codes, and how to fix errors. *Last updated: August 2026. Reflects current payment procedures and account numbers.* Every month, as a Serbian paušalac, you must make four separate bank transfers to four different government treasury accounts. Get a reference number wrong, and your payment goes to the right institution but gets attributed to the wrong person — meaning you're simultaneously overpaying on one obligation and accumulating penalty interest on another, even though you paid the correct total. This happens more often than you'd think. This guide walks you through the entire monthly payment process: which accounts to pay, how to construct the reference numbers, what the payment codes mean, how to use the ePorezi portal, and how to fix errors if they happen. --- ## The four monthly payments Your annual rešenje (tax decision) from the Poreska uprava specifies exactly four monthly obligations: ### 1. Porez na prihode od samostalnih delatnosti (Income Tax) This is the lump-sum income tax — 10% of your assessed paušalni prihod (which is not your actual income, but a figure calculated by the Tax Authority based on your activity code, location, and other factors). **Typical monthly amount:** Varies widely by activity code and municipality. For IT-related codes in Belgrade, commonly 3,000-8,000 RSD/month. ### 2. Doprinos za PIO (Pension Insurance) Your pension and disability insurance contribution — 24% of the assessed base. This is always the largest of the four payments. **Typical monthly amount:** Commonly 7,000-20,000 RSD/month depending on your assessed base. ### 3. Doprinos za zdravstveno osiguranje (Health Insurance) Health insurance contribution — 10.30% of the assessed base. This gives you access to the public health system (RFZO). **Typical monthly amount:** Commonly 3,000-8,000 RSD/month. ### 4. Doprinos za nezaposlenost (Unemployment Insurance) Unemployment insurance contribution — 0.75% of the assessed base. The smallest payment. **Typical monthly amount:** Commonly 200-600 RSD/month. ### Exception: dopunska delatnost If you're a paušalac running your business as a **side activity** (dopunska delatnost) while employed full-time elsewhere, you pay only items 1 and 2 (income tax and PIO). Your employer covers health and unemployment insurance through your salary. --- ## Payment deadline **All four payments are due by the 15th of the following month.** January taxes are due February 15. If the 15th falls on a weekend or holiday, the deadline shifts to the next business day. Missing the deadline triggers daily penalty interest from the 16th. The first payment of the year is typically due in **February** (for January), assuming you received your new rešenje in January. The obligation and its amount come from the rešenje; the deadline comes from the calendar (ZPDG čl. 110 t. 1 — 15 days after the end of each month), not from the day the rešenje reached you. A rešenje delivered electronically counts as served *"danom postavljanja na portal Poreske uprave"* — the day it is posted to the portal (ZPPPA čl. 36) — whether or not you have logged in to read it. If the rešenje arrives late, you may need to make retroactive payments for the missed month(s). Do not assume the interest is waived because the delay was theirs: ZPPPA čl. 75 st. 1–4 runs interest from the day after the due date and sets out no exception for a delay on the Tax Authority's side. If you believe a delay was caused by the authority, raise it with the Poreska uprava rather than treating the interest as written off. --- ## Anatomy of a payment slip Each payment requires a filled-out nalog za prenos (transfer order) or its electronic equivalent in your bank's online system. Here are the fields you need to understand: ### Platilac (Payer) Your full business name and address. Your bank usually pre-fills this. ### Svrha plaćanja (Purpose of payment) A description of what you're paying. Standard format: "Porez na prihode od sam. delatnosti za [mesec] [godina]" — or similar for each payment type. Some banks accept brief descriptions; others want the full name. ### Primalac (Recipient) The recipient is always the **Republika Srbija** (Republic of Serbia), with the specific treasury account number for each payment type. ### Šifra plaćanja (Payment code) - **253** — for non-cash payments (bank transfer, which is what you'll use) - **153** — for cash payments at a bank counter Always use **253** if paying through online banking. ### Valuta (Currency) Always **RSD** (Serbian dinars). ### Iznos (Amount) The exact monthly amount from your rešenje for this specific payment. ### Račun primaoca (Recipient account) The treasury account number. This is different for each of the four payments — see section below. ### Model and Poziv na broj (Reference number) This is where most errors happen. The payment reference consists of two parts: **Model:** Always **97** for paušal tax payments. **Poziv na broj (BOP — Broj odobrenja za plaćanje):** This is a unique code assigned to YOU in your rešenje. It identifies you as the payer. It changes every year when you receive a new rešenje. The BOP typically follows the structure: `[kontrolni broj]-[PIB]-[oznaka]`. The exact format is printed on the sample payment slips (primer uplatnice) that come with your rešenje. **You must use the exact BOP from your current year's rešenje.** Using last year's BOP is the most common payment error — it either routes the payment to the wrong taxpayer account or leaves it in limbo. Update your payment templates every January. --- ## The four treasury accounts Each payment goes to a different account. These account numbers are specified in your rešenje — **use the ones from your rešenje, not hardcoded values from the internet,** as they can theoretically vary. A Serbian public-revenue account is written in three parts, `840-XXXXXXXXX-XX`: the 840 treasury group, a nine-digit revenue account, and a two-digit control number. Anything printed in another shape has been mistranscribed. The accounts below are the ones prescribed for these four obligations in the Pravilnik o uslovima i načinu vođenja računa za uplatu javnih prihoda i raspored sredstava sa tih računa: | Payment | Treasury account | |---------|-----------------| | Porez na prihode (Income Tax) | 840-711122843-32 | | PIO (Pension) | 840-721313843-74 | | Zdravstveno (Health) | 840-721325843-61 | | Nezaposlenost (Unemployment) | 840-721331843-06 | All four start with **840**, the prefix for Serbian Treasury (Uprava za trezor) accounts. Your bank's payment form validates the control number, so a mistyped account is rejected before the money leaves — but a *valid* account for the wrong obligation is not, which is why the number has to come off your rešenje. **Always verify these account numbers against your rešenje.** The rešenje is the authoritative document for your specific obligations. If it shows a different account number, use the one from the rešenje — not values found online. --- ## Step-by-step: making payments through online banking Here's the practical process using a typical Serbian bank's online banking system (Raiffeisen, Intesa, Komercijalna, etc.): ### Step 1: Log in and navigate to transfers Open your bank's online banking portal. Navigate to domestic transfers (domaći nalog za prenos / nalog za uplatu javnih prihoda). Some banks have a specific "Uplata javnih prihoda" (Public revenue payment) form that's pre-structured for tax payments. ### Step 2: Fill in payment 1 of 4 For the income tax payment: - **Račun primaoca:** The treasury account from your rešenje (e.g., 840-711122843-32) - **Šifra plaćanja:** 253 - **Model:** 97 - **Poziv na broj:** Your BOP from the rešenje - **Iznos:** The monthly income tax amount from your rešenje - **Svrha:** "Porez na prihode od sam. del. za [month] [year]" ### Step 3: Repeat for payments 2, 3, and 4 Each payment is a separate transfer — you cannot combine them. Change the recipient account, amount, and description for each one. The model (97) and poziv na broj (BOP) remain the same across all four payments. ### Step 4: Verify and submit Double-check each transfer before confirming. The most common errors: - Wrong recipient account (mixing up the four treasury accounts) - Last year's BOP instead of this year's - Swapped amounts (putting the PIO amount on the health insurance payment) ### Step 5: Save confirmations Keep the payment confirmations (PDF or screenshot). They're your proof of payment if there's ever a discrepancy. ### Pro tip: templates Most Serbian online banking systems let you save transfer templates. Create four templates — one for each payment — with all the static fields pre-filled. Each month, you just open the template, verify the amount, and submit. This eliminates most manual errors. --- ## Using ePorezi to verify payments The **ePorezi portal** (eporezi.purs.gov.rs) is the Tax Authority's electronic system where you can: - View your rešenja and BOP codes - Check your payment history (stanje na kartici poreskog obveznika) - See if any payments are overdue or misattributed - Download sample payment slips with QR codes To access ePorezi: 1. You need a **kvalifikovani elektronski sertifikat** (qualified electronic certificate) — available from MUP (for personal ID cards with chip) or commercial providers 2. Register at eporezi.purs.gov.rs using the certificate 3. Navigate to "Stanje na kartici" to see your tax account status **Check ePorezi quarterly.** It's the fastest way to catch misattributed payments before penalty interest accumulates. Don't wait until an inspection to discover errors in your tax account. --- ## What happens if you make a payment error ### Wrong BOP / reference number If you used the wrong BOP, your payment arrives at the treasury but can't be matched to your tax account. It sits in a "neraspoređena uplata" (unallocated payment) state. **Fix:** File a request (zahtev za preknjižavanje) at your local Poreska uprava office, providing the incorrect payment receipt and the correct BOP. The tax office will reallocate the payment. This typically takes 2-4 weeks. ### Wrong treasury account If you sent the PIO amount to the health insurance account (or any similar mix-up), the money is attributed to the wrong obligation. **Fix:** Same procedure — file a preknjižavanje request. You'll need both the incorrect and correct account numbers and the payment receipt. ### Missed payment entirely If you miss the 15th deadline, tax interest begins accruing the day after the due date at the NBS reference rate **+ 10 percentage points** (ZPPPA čl. 75). Note the name: this is not *zatezna kamata*, the civil default interest, which runs at the reference rate + 8 percentage points. Interest is calculated per calendar day, so pay as soon as you notice. Interest accrues automatically. A fine is a separate matter: it arises through a tax control procedure, not as a surcharge on every late payment, and where a return was filed but the tax left unpaid it is reported at 10%–50% of the tax determined in control, with a minimum of 50,000 RSD for an entrepreneur. Persistent non-payment can also trigger enforced collection (prinudna naplata). See [the guide to late payment](/articles/late-payment-interest). ### Payment to wrong person (wrong PIB in BOP) This is the most problematic error. If your BOP contains a transposed digit that happens to match another taxpayer, your payment effectively paid someone else's taxes. **Fix:** Requires a formal request at the Poreska uprava, possibly involving both taxpayers' records. This is slower and more complex. Prevention is the only good strategy — double-check the BOP. --- ## Annual rhythm: when amounts change Your monthly payment amounts are **fixed for the year** by the rešenje. They don't change month to month based on your actual income (that's the entire point of the paušal system). New amounts are set each January when the Tax Authority issues updated rešenja. The new rešenje reflects: - Updated municipal average wage (prosečna mesečna zarada) - Your activity code coefficient - Any changes in location, age, or business duration factors - The annual cap on increases (currently limited to **10% growth** year-over-year per the Uredba, extended through end of 2027) When you receive a new rešenje in January, update your payment templates with the new amounts and BOP. The old amounts apply to December (paid in January); the new amounts apply starting with January (paid in February). --- ## A monthly checklist Here's a simple routine to follow each month: **By the 10th of each month:** - Open your four payment templates in online banking - Verify amounts match current year's rešenje - Verify BOP matches current year's rešenje - Submit all four payments **By the 15th:** - Confirm all four payments show as completed in your bank history - Save payment confirmations **Quarterly (optional but recommended):** - Check ePorezi "stanje na kartici" to verify all payments are correctly attributed - Flag any discrepancies for resolution --- ## Key takeaways 1. **Four separate payments, four separate accounts.** Income tax, PIO, health, unemployment — each goes to a different treasury account. Never combine them. 2. **Model 97, always.** The BOP (poziv na broj) from your rešenje is your unique payment identifier. It changes every year. 3. **Deadline is 15 days after the end of the month** (ZPDG čl. 110 t. 1). Late payment accrues daily tax interest at the NBS reference rate + 10 percentage points. 4. **Save templates in your online banking.** Pre-fill the static fields, update amounts and BOP in January, and reduce monthly effort to 5 minutes. 5. **Check ePorezi periodically.** It's the only way to confirm payments are correctly attributed on the Tax Authority's side. 6. **If you make an error, file a preknjižavanje request promptly.** Misattributed payments are fixable but take time — don't let them compound. 7. **When in doubt, use the exact values from your rešenje.** It's the authoritative document. Don't rely on amounts or account numbers from the internet or from last year.