Regulatory updates - Bosnia and Herzegovina

Following the House of Representatives of Parliament's acceptance of the Draft Law on Fiscalization of Transactions on December 17, 2024, the Federal Ministry of Finance initiated a public hearing. This hearing will take place from January 1 to March 1, 2025. Its goal is to develop an efficient, high-quality legal solution that is as practical and enforceable as possible.

Comments and feedback must be submitted using the form available for download alongside the Draft Law on the Federal Ministry’s website. Once completed, the form can be sent to the Federal Ministry by mail or email.

The next step will involve preparing a Proposal of the Law, which will be based on the Draft Law and the feedback received from the public.

On November 12, 2024, the Draft Law on Fiscalization of Financial Transactions in the Federation of BIH was published. The main purpose is to prevent tax evasion using technological systems providing secure real-time information for all transactions in the country. The required bylaws and implementation timelines are yet to be published.   

Expected scope of the mandate 

The Draft Law defines an e-invoice as a bill issued and received in a structured format, complying with the EU standard, and enabling automatic electronic processing.  

It outlines the requirements for mandatory e-invoicing in the B2G, B2B, and B2C sectors and real-time reporting invoice data to the tax administration. Some sectors are out of scope e.g. security and defense, health, and social protection activities.
 

Transactions in scope are but are not limited to, the sale of goods and services including the transfer of property.  

CTC-model to be defined 

There is no framework regulating e-invoicing in the country today. The Draft Law outlines a central fiscalization platform (CFP) and so-called Electronic Fiscal Systems (EFS). The EFS includes an electronic transaction recording system (ESET) and/or fiscal equipment. 

ESET software for invoice issuance, reception, and reporting invoice data to the tax administration may be a desktop version of the fiscal system, an integrated accounting system, or a cloud application fulfilling the requirements specified in the Draft Law. 
 

EFS for issuing and receiving receipts includes hardware e.g. cash register and/or electronic device, for example, a laptop or mobile phone used to issue receipts.   

Taxpayers should be able to validate the invoice/receipt on the platform either by a verification number or a QR code. 

Bosnia and Herzegovina's House of Peoples have passed a law raising the threshold for mandatory VAT registration from 50 000 to 100 000 BAM. This law was proposed by the House of Representatives of the Republic of Srpska BiH to reflect the inflationary trends and price increases of goods and services.

The Official Gazette of 24 October 2023 reported that this law would enter into force on the eighth day after its official publication (2 December 2023).

Likewise, when it comes to the registration of taxpayers, the procedure of registering in the Unified Register of Taxpayers of Indirect Taxes is carried out according to the regulations in force at the time.