Developments in the tax legislation

• The VAT exemption for imports of small value shipments is amended to apply only to small shipments of non-commercial nature sent from one individual to another. The exemption previously applied to all small value shipments, irrespective of whether the shipment was a result of a commercial transaction.T he amount of small value shipments remains the same - EUR 22, and as previously, the exemption does not apply for alcohol and alcoholic beverages, perfumes, tobacco and tobacco products. This change is applicable from 18 December 2025.
• The applicability of the preferential VAT rate of 5% for residential buildings and apartments is prolonged to 31 December 2028.
• “Cosmetic changes” regarding the place of supply of services related to immovable property and services provided by tour operators.

• A new Rulebook on the Manner of Calculation and Payment of the Top-up Tax has been published in Official Gazette No. 270 from 31 December 2025. The rulebook specifically refers to OECD models and rules for calculation of top-up tax, and prescribes the forms for Qualified Domestic Minimum Top-Up Tax (QDMTT), for Income Inclusion Rule (IIR) and for Undertaxed Profit Rule (UTPR).

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Srdjan Randjelovic
Partner
Tel.: +389 2 313 52 20

Koce Jovanov
Senior Manager, Tax
Tel: +389 2 313 52 20