Resetting of deadline for submission of financial statements and income tax returns

On 16 April 2020, the Government of the Republic of Serbia adopted a Regulation on delaying the deadlines for holding the regular session of a company assembly and for submitting annual and consolidated financial statements of companies, cooperatives, other legal entities and entrepreneurs, as well as deadlines for filing income tax returns and taxes on income from self-employment, the validity of licenses of certified auditors and licenses for assessing the value of real estate that expire during the state of emergency caused by the COVID-19 disease caused by the SARS-CoV-2 virus („Regulation“).

The Regulation regulates the postponement of deadlines for:

• holding a regular session of the company assembly;
• submission of annual financial statements to the Securities Commission;
• submission of the annual and consolidated financial statements of companies, cooperatives, other legal entities and entrepreneurs for 2019 to the Business Registers Agency;
• filing corporate and personal income tax returns;
• validity of licenses of certified auditors and licenses for real estate valuation.

Deadline for holding the regular session of the assembly

The Company Law stipulates that the regular session of the assembly is held once a year, not later than six months after the end of the business year. The Regulation stipulates that the regular meeting of the assembly in 2020 may be held within 90 days from the date of termination of the state of emergency.

Deadline for submission of annual financial statements to the Securities Commission

Deadline for submission of annual reports, or annual financial statements, with the auditor’s report of all taxpayers whose reporting is regulated by the:

• Law on Capital Market
• The Law on Investment Funds
• the Law on Alternative Investment Funds with a Public Offering

shall be moved to 60 days from the date of termination of the state of emergency.

Deadlines for submission of annual financial reports to the Business Registers Agency

The Regulation stipulates that the deadlines that are regulated by the Accounting Law are postponement as follows:

• The deadline for submission of the regular annual financial statements, which is prescribed by 30 June, is postponed to 90 days from the date of termination of the state of emergency;
• The deadline for submission of consolidated annual financial statements, which is prescribed by 31 July, is postponed to 120 days from the date of termination of the state of emergency.
• The deadline for submission of financial statements, which is prescribed within 60 days from the date of preparation of the financial statements, is postponed to 30 days from the date of termination of the state of emergency, provided that the deadline for the preparation of the financial state of emergency expires during the state of emergency.

These deadlines apply to legal entities that have a business year different from the calendar year, provided that the deadline for submission of the financial statements of the legal entities expires during the state of emergency.

Deadlines for filing corporate and personal income tax returns

Regarding the deadlines for filing corporate income tax and self-employment tax, the Regulation stipulates the following dynamics:

• corporate taxpayers file a corporate income tax return within 90 days from the date of termination of the state of emergency, for corporate taxpayers with a tax period equal to the calendar year, and for corporate income taxpayers who are tax period different from the calendar year
• taxpayers of self-employment income tax who keep books of accounts in accordance with the Law on Personal Income Tax submit a tax return and tax balance within 90 days from the day of the end of the state of emergency

Extension of licenses of certified auditors

The Regulation shall apply to the period of validity of the audit license and the renewal of the audit license prescribed by Article 7 of the Audit Law, which expire during the state of emergency, shall be considered expired after 30 days from the date of termination of the state of emergency.

Extension of licenses of authorized valuers

The Regulation applies to the deadlines prescribed by Article 11 of the Real Estate Appraisers Law. Deadlines for the license of real estate appraisers expiring during the state of emergency and 30 days from the date of termination of the state of emergency shall be considered expired after the expiration of 60 days from the date of termination of the state of emergency.

The Regulation entered into force on 16 April 2020.