Tax Exemption Guidelines.pdf

This document, including all data, information and materials contained herein, constitutes a trade secret in terms of Article 2 of the Law on the Protection of Trade Secrets (“Official Gazette of the Republic of Serbia”, No. 53/2021), and confidential information owned by EXPO 2027 d.o.o. Belgrade (Stari Grad). The document is intended solely for internal use and/or for the designated recipient, and may be used only for the purpose for which it has been provided. Any unauthorised use, disclosure, reproduction, distribution or transmission of the document, or of any data, information and/or materials contained therein, to any third party without the prior written consent of EXPO 2027 d.o.o. Belgrade (Stari Grad) is strictly prohibited. All personal information that may be contained in this document shall be processed and protected in accordance with the provisions of the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia”, No. 87/2018), the Company’s internal acts, and other relevant regulations.

This document, together with all data, information and materials contained herein, constitutes a trade secret in terms of Article 2 of the Law on the Protection of Trade Secrets (“Official Gazette of the Republic of Serbia”, No. 53/2021), and confidential information owned by EXPO 2027 d.o.o. Belgrade (Stari Grad). The document represents a working version and may contain preliminary or incomplete information. Its contents do not constitute final positions, conclusions or binding information. It is intended solely for internal use and/or for cooperation with the designated recipient and may be used only for the purpose for which it has been provided. Any unauthorised use, disclosure, reproduction, distribution or transmission of this document, or of any data, information and/or materials contained herein, to any third party without the prior written consent of EXPO 2027 d.o.o. Belgrade (Stari Grad) is strictly prohibited. All personal data that may be contained in this document are processed and protected in accordance with the provisions of the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia”, No. 87/2018), the Company’s internal acts, and other relevant regulations.

TAX

EXEMPTION

GUIDELINES

Version 1.0 20 October 2025 Belgrade, Serbia

1 Introduction

62 Tax Exemptions

3 Charges for the Occupation of Public Space within the Exhibition Site

4 Fiscalisation

5 Electronic Invoicing System („SEF“)

Contents

3 TAX EXEMPTION GUIDELINES

According to the Agreement, the tax exemptions granted as privileges to Official Participants include: (i) exemption from corporate income tax; (ii) exemption from property tax for purposes related to the participation in the Exhibition;

(iii) exemption from payment, refund and reimbursement of VAT; (iv) exemption from excise duties on electricity consumed in the pavilions and on fuels and lubricants for up to two vehicles imported for official use; (v) exemption from personal income tax and related mandatory social security contributions on income paid by the Office of Section Commissioner in the Republic of Serbia, provided that such income is directly related to the Exhibition and/or produced outside the Republic of Serbia, provided that it is directly related to the Exhibition; and (vi) exemption from charges for the occupation of public space within the Exhibition Site.

These Guidelines have been prepared in accordance with the Agreement, Special Regulation No. 7 governing customs and handling, and any particular rates and charges, and Special Regulation No. 12 concerning the privileges and advantages of Section Commissioners and their staff, for the purpose of providing Official Participants with detailed information on procedures and other tax-related matters, in order to enable them to exercise the privileges set forth herein.

These Guidelines have been drafted based on the relevant regulations in force as of 20 October 2025 and are subject to subsequent amendments.

1 introduction

1.1 Purpose

4 TAX EXEMPTION GUIDELINES

1.2 Definitions

In this Guidelines the following words and phrases shall have the following meanings.

Abbreviations Definitions

Bureau International des Expositions (BIE);

The Convention relating to International Exhibitions, signed in Paris on 22 November 1928, as amended and supplemented;

The Agreement between the Republic of Serbia and the Bureau International des Expositions on the privileges and benefits necessary for the participation in the Exhibition;

The Internationally Recognised Exhibition Expo 2027 Belgrade, to be held in Belgrade, Republic of Serbia, between 15 May and 15 August 2027;

The operation of food services or restaurants, merchandise sales or service provision by the Office of Section Commissioner, in accordance with the Participation Contract;

BIE

Convention

Agreement

Exhibition

Commercial Activities

The electronic system of the Tax Administration of the Republic of Serbia through which can be used by persons authorised by the Office of Section Commissioner, holding a qualified electronic certificate, to submit VAT registration form and other relevant tax returns. Access to the ePorezi Portal (eTaxes Portal) requires the dedicated ePorezi application, available at the following link: ePorezi Portal (eTaxes Portal).

ePorezi Portal (eTaxes Portal)

The General Regulations of the Exhibition as approved at the 175th General Assembly of the BIE;

General Regulations

These guidelines on tax exemptions foreseen as privileges for Official Participants, prepared, updated, and shared by the Organiser with the Official Participants.

Guidelines

A digital platform enabling the submission and approval of all key Expo documents, as well as all communication with the Expo Organisation through a single online portal;

IP portal

The Convention, the relevant legislation of the Republic of Serbia, the Agreement, the General and Special Regulations, the Guidelines, and any additional instructions or decisions issued by the Organiser in accordance with the General and Special Regulations;

Laws and Regulations

A temporary legal entity of the Official Participant which has the status of a domestic legal entity in the Republic of Serbia, established solely for the purpose of participating in the Exhibition;

Office of Section Commissioner

A state or intergovernmental organisation that has received and accepted the official invitation of the Republic of Serbia to participate in the Exhibition;

Official Participant

The physical and online platform which will be set up by the Organiser to provide Participants with information, and to handle submissions and applications of Participants in relation to their participation in the Exhibition;

One-Stop Shop https://www.purs.gov.rs/e-porezi/portal.html

5 TAX EXEMPTION GUIDELINES

Control and Guide in the Guidelines are marked with codes C-00 – Control and G-00 – Guide. These codes consist of a letter (C or G) and a two-digit number indicating the sequence of the mandatory or recommended actions:

C-00 – Control refers to mandatory actions or requirements that Official Participants must undertake or comply with, as described in the Guidelines.

G-00 – Guide indicates recommended actions suggested to the Official Participants by the Organiser.

1.3 Control and Guides

The contract entered between the Organiser and each Official Participant, to establish the terms under which the Official Participants will take part in Exhibition;

Participation Contract

The representative appointed by each Official Participant in the Exhibition in accordance with Article 13 of the Convention;

Section Commissioner

The staff of the Office of Section Commissioner of each Official Participant shall include: the Section Commissioner, the deputy Section Commissioner, the Pavilion Director and employees or otherwise engaged personnel of the Office of Section Commissioner;

Section Staff

The Special Regulations of the Exhibition referred to in Article 34 of the General Regulations;

Special Regulations

Value added tax;VAT

“EXPO 2027 d.o.o. Belgrade, with registered headquarters at 5 Kralja Milana Street, Belgrade-Stari Grad, the Republic of Serbia, solely owned by the Republic of Serbia and established to prepare, organise, operate and manage the Exhibition;

Organiser

6 TAX EXEMPTION GUIDELINES

In accordance with the Agreement, Offices of Section Commissioners are exempt from the obligation to pay tax on corporate income generated from Commercial Activities, as well as from the sale of items, installations, or other exhibits presented at the Exhibition, and are not required to submit a corporate income tax return.

Offices of Section Commissioners are entitled to corporate income tax exemption automatically, without any need for additional applications or procedures.

In accordance with the Agreement, Offices of Section Commissioners are exempt from the obligation to pay property tax in the Republic of Serbia. This tax exemption applies to property that the Offices of Section Commissioners own, lease, hold, or use exclusively for the purpose of participating in the Exhibition. The exemption applies until 31 December 2027.

Offices of Section Commissioners are entitled to exemption from property tax automatically, without the need to submit a property tax return or undertake additional applications or procedures.

VAT is a consumption tax that is levied and paid on the import of goods into the Republic of Serbia and on the supply of goods and services within the Republic of Serbia for a consideration.

2 Tax

2.2 Property Tax

2.3 VAT

2.3.1 VAT Registration

(i) Obligation to register for VAT

VAT registration is mandatory for all Offices of Section Commissioners that will carry out Commercial Activities at the Exhibition and that, on that basis, generate income exceeding RSD 8,000,000 (approximately EUR 68,250) over the previous 12-month period.

C-01 Once the income from Commercial Activities exceeds the above threshold, the Offices of Section Commissioners must submit a VAT registration form via the ePorezi Portal (eTaxes Portal) within five days.

C-02 Upon exceeding the above threshold, the Offices of Section Commissioners must calculate and report VAT in accordance with the Law and Regulations.

G-01 Offices of Section Commissioners may authorise other persons to submit the VAT registration form and other relevant tax returns via the ePorezi Portal (eTaxes Portal) by submitting the PEP Form, which is available at the following link: PEP Form. The PEP Form must be submitted electronically to the Tax Administration via the following email address: pep.expo2027@purs.gov.rs.

(ii) Voluntary VAT Registration

Offices of Section Commissioners may voluntarily register for VAT by submitting a registration form to the Tax Administration via the ePorezi Portal (eTaxes Portal) at any time prior to exceeding the above-mentioned income threshold from Commercial Activities.

VAT registration may also be performed simultaneously with the establishment of a Office of Section Commissioner.

When submitting the registration application for the establishment of the Office of Section Commissioner, the https://purs.gov.rs/upload/media/2025/2/4/497178/ObrazacPEP.pdf mailto:pep.expo2027@purs.gov.rs

7 TAX EXEMPTION GUIDELINES

2.3.2 VAT Exemptions

The Office of Section Commissioner shall be exempt from VAT on:

• the import of up to two vehicles for official use and respective spare parts; and

• the import of goods intended for the performance of institutional and non-commercial activities at the Exhibition, which shall include:

a. goods required for the construction, installation, exhibition, operation, or dismantling of their pavilions at the Exhibition;

b. goods or services directly related to the operation of the pavilion or to any presentations on the Exhibition Site during the Exhibition period; and

c. goods for official use, including office supplies.

This exemption shall apply until 31 December 2027.

Goods qualifying under each of the three categories include, but are not limited to, the examples listed below.

Section Staff, their family members and persons necessary for their care, as well as members and staff of the BIE, shall be exempt from VAT on goods imported for personal use, under the most favorable limitations and conditions applicable to diplomatic and consular personnel in the Republic of Serbia, including furniture in reasonable quantities and one motor vehicle.

Authorised persons shall be entitled to import spirits (containing 20% alcohol or more), cigarettes, cigars, and perfumes for personal use without any VAT payment, subject to the following annual quotas:

• 300 bottles of spirits;

• 40,000 cigarettes;

• 1,000 cigars; and

• 24 perfumes.

Category Goods eligible for VAT exemption

Construction materials, such as steel, glass, wood, bricks, plaster, coatings and paints;

Pavilion furniture (chairs, tables, shelves, etc.);

Construction equipment, such as hand and power tools and construction scaffolding;

Electronic equipment, such as projectors, television sets;

Corporate gifts, promotional gifts;

Electronic equipment, such as computers, laptops, telephones, computer peripherals (mice, keyboards, printers, scanners);

Office supplies, such as folders, binders, notepads, staplers, paper materials.

Category a) – construction, installation, exhibition, operation or dismantling of the pavilion

Category b) – operation of the pavilion or a presentation at the Exhibition

Category c) – official use authorised person may check the VAT registration checkbox, based on which the Tax Administration will complete the VAT registration of the Office of Section Commissioner.

G-02 Considering that Offices of Section Commissioners will not carry out Commercial Activities prior to the opening of the Exhibition, it is recommended that they do not register for VAT during that period.

Exhibits, and any other items necessary for presentation at the Exhibition, including supporting materials and equipment, systems for the installation and mounting of exhibition exhibits;

8 TAX EXEMPTION GUIDELINES

Offices of Section Commissioners shall be entitled to a reimbursement or refund of VAT paid on:

a. the procurement of goods, services, and works for the purposes of construction, installation, installation, operation, or dismantling of their Pavilions at the Exhibition;

b. the procurement of goods or services directly related to the operation of the Pavilion or any presentation at the Exhibition Site during the Exhibition period;

c. the procurement of goods for official use, including office supplies;

d. leasing of buildings or parts thereof for the accommodation of the Section Staff;

e. the supply of water, electricity, and heating fuel, as well as the provision of telephone and other communication services for the Pavilions of the Offices of Section Commissioners and for Section Staff’s residences; and

f. the procurement of fuel and lubricants for up to two vehicles imported for official use, under the most favorable conditions granted to diplomatic and consular personnel and international organisations in the Republic of Serbia.

In addition to the examples listed in the table above, goods and services eligible under categories a), b), and c) shall include, but shall not be limited to, the following examples:

2.3.4 Right to VAT Reimbursement and Refund

Category Goods and Services Eligible for VAT Refund or Reimbursement

Spatial planning services, architectural services, interior design services, landscaping services, etc.;

Freight forwarding and logistics services;

Waste management services;

Event organisation and management services, including event management companies, procurement or rental and installation of equipment such as audio and visual systems;

Services and goods provided by all contractors necessary for the smooth operation of the pavilions or installations at the Exhibition, such as cleaning, security, and catering services;

Transportation services for personnel and official delegations;

Postal and courier services

Category a) – construction, installation, exhibition, operation or dismantling of the pavilion

Category b) – operation of the pavilion or a presentation at the Exhibition

Category c) – official use

C-03 Any request for VAT reimbursement shall be filed to the Tax Administration via the ePorezi Portal (eTaxes Portal).

C-04 The authorised representative of the Office of Section Commissioner must sign and submit the reimbursement request within 30 days from the first day of the month following the month for which the reimbursement is being claimed.

The Tax Administration shall decide on the request by issuing a decision within 15 days as of the date of filling the request and shall deliver the decision to the Office of Section Commissioner via the ePorezi Portal (eTaxes Portal).

2.3.5 VAT Reimbursement

2.3.3 VAT Exemption Procedure

The procedure and conditions for exercising the right to VAT exemption on the import of the above-listed goods by the Offices of Section Commissioners, or by persons authorised by the Offices of Section Commissioners, will be defined at a later stage. All relevant information will be made available in the updated version of the Guidelines.

9 TAX EXEMPTION GUIDELINES

Offices of Section Commissioners are exempt from paying excise duty on electricity consumed within pavilions and on fuel and lubricants procured for up to two vehicles imported for official use.

The service provider shall neither calculate nor display the excise duty on invoices for electricity consumed in the pavilions. Accordingly, the Offices of Section Commissioners shall enjoy this privilege without the need for additional requests or procedures.

C-06 In order to exercise the right to exemption from payment of excise duty for the procurement of fuel and lubricants for up to two vehicles imported for official use, each Office of Section Commissioner must provide the seller with:

• a photocopy of the excise exemption certificate; and

• the original official purchase order, available at the following link: SNA Form.

The excise exemption certificate shall be issued by the Ministry of Foreign Affairs of the Republic of Serbia, based on a request filed by the Office of Section Commissioner to [insert].

C-07 Prior to issuing the first official purchase order for fuel and lubricants for up to two vehicles imported for official use, the Office of Section Commissioner shall provide the Tax Administration with the details of the persons authorised for issuing official purchase orders, as well as the specimen signature cards (form available at the following link: OP Form). The said documentation shall be submitted electronically to the Tax Administration via akciza.obrazacsna@ purs.gov.rs.

In accordance with the Agreement, the Section Staff, family members of the Section Commissioner, deputy Section Commissioner, and Pavilion Director, as well as individuals involved in artistic, cultural, and sports events organised by the Office of Section Commissioner as a part of the Exhibition, provided they are not citizens of or have a permanent residence in the Republic of Serbia, shall be exempt from all forms of direct taxation on income that:

• is paid to them by the Office of Section Commissioner, if directly related to the Exhibition; and/or

• is produced outside the Republic of Serbia, if directly related to the Exhibition.

For income paid to such individuals, provided they do not hold citizenship or have a place of permanent residence in the Republic of Serbia, no individual income tax return for calculated taxes and contributions for mandatory social insurance shall be submitted.

2.4 Excise Duty

2.5 Individual Income Tax

Offices of Section Commissioners may claim a refund of the difference between the VAT paid on the purchase of goods and services (input VAT) and the VAT charged to their customers (output VAT), provided that the input VAT exceeds the output VAT. If they do not claim the refund, the excess VAT paid may be used as a tax credit to offset future tax liabilities.

C-05 The right to VAT refund is exercised by filing a VAT return to the Tax Administration via the ePorezi Portal (eTaxes Portal), provided that the person authorised by the Office of Section Commissioner selects the “YES” option in Section Eleven of the VAT return, which relates to the refund of excess VAT paid.

The Tax Administration shall execute the VAT refund to the Office of Section Commissioner within 45 days from the expiration of the legally prescribed deadline for filing the VAT return.

2.3.6 VAT Refund

https://www.paragraf.rs/obrasci/7079_ID.pdf https://www.paragraf.rs/obrasci/Prilog_2_ID4012.pdf https://www.paragraf.rs/obrasci/Prilog_2_ID4012.pdf mailto:akciza.obrazacsna@purs.gov.rs mailto:akciza.obrazacsna@purs.gov.rs

10 TAX EXEMPTION GUIDELINES

C-09 Offices of Section Commissioners that intend to engage in Commercial Activities at the Exhibition are required to use an electronic fiscal device for issuing fiscal invoices.

In accordance with the regulations governing fiscalisation, the electronic fiscal device must contain a security element that enables the Office of Section Commissioner to digitally sign each fiscal invoice. Taxpayers subject to fiscalisation are permitted to use only fiscal devices accredited by the Tax Administration. The list of accredited devices is available on the Tax Administration’s website at the following link: Register of Approved Elements of Electronic Fiscal Devices.

C-10 The fiscalisation procedure shall be carried out in two steps, with the assistance of appointed accountants, exclusively through the ePorezi Portal (eTaxes Portal): (i) submission of the application to generate a unique designation of business premises and establishment (guidelines available at: Instructions for the submission of the application to generate a unique designation); (ii) submission of the application for the issuance of the security element, no earlier than one day after the assignment of the unique designation (guidelines available at: Instructions for the submission of the application for issuance of the security element).

C-11 Offices of Section Commissioners that are registered for VAT are required to use the electronic invoicing system (SEF):

• when receiving invoices from other business entities listed as SEF users;

• when issuing invoices to other business entities listed as SEF users.

SEF access registration can be carried out via the web interface available at the following link: eInvoices. Initial access for registration purposes is performed by the Section Commissioner or their deputy. The identity of the Section Commissioner or their deputy is verified through the Electronic Identification Portal, using a high-assurance electronic identification scheme. This simply means that SEF is initially activated by using the electronic qualified signature of either Section Commissioner or their deputy, while upon such activation, the accountant or any other person may be

4 Fiscalisation

5 Electronic Invoicing System

(„SEF“)

In accordance with the provisions of the Agreement, Offices of Section Commissioners shall be exempt from the obligation to pay charges for the occupation of public space within the Exhibition site.

C-08 However, each Office of Section Commissioner is required to pay the environmental protection and improvement fee as well as local administrative fees. Such fees and charges can be paid via the ePorezi Portal (eTaxes Portal)..

for the Occupation of Public Space within the Exhibition Site

3 Charges http://www.purs.gov.rs/eFiskalizacija/registar-odobrenih-elemenata-efu.html https://www.purs.gov.rs/eFiskalizacija/korisnicka_uputstva/7667/korisnicko-uputstvo-za-dostavljanje-podataka-i-generisanje-jedinstvene-oznake-o-poslovnom-prostoru-i-poslovnim-prostorijama-elektronskim-putem.html https://www.purs.gov.rs/eFiskalizacija/korisnicka_uputstva/7667/korisnicko-uputstvo-za-dostavljanje-podataka-i-generisanje-jedinstvene-oznake-o-poslovnom-prostoru-i-poslovnim-prostorijama-elektronskim-putem.html https://www.purs.gov.rs/eFiskalizacija/korisnicka_uputstva/7985/uputstvo-za-podnosenje-prijave-za-izdavanje-bezbednosnog-elementa.html https://www.purs.gov.rs/eFiskalizacija/korisnicka_uputstva/7985/uputstvo-za-podnosenje-prijave-za-izdavanje-bezbednosnog-elementa.html https://efaktura.mfin.gov.rs/login

11 TAX EXEMPTION GUIDELINES

authorised to undertake any further actions in regard to SEF use. As of the date of registration, the Office of Section Commissioner is considered a SEF user, and information about the Office of Section Commissioner is entered into the SEF users’ list. Consequently, from the date of registration, the Office of Section Commissioner can technically access SEF either directly or via an information intermediary. Please note that direct access to SEF is free of charge.

Office of Section Commissioner may use SEF directly in two ways:

• through the user interface, via a web browser;

• through an application programming interface (API), which enables integration with SEF.

After registration, the Office of Section Commissioner may, using the appropriate SEF functionality, authorise a designated person (typically an accountant) to use SEF on its behalf and for its account for the aforementioned purposes, as well as for VAT transaction reporting and other purposes stipulated by Laws and Regulations.

Offices of Section Commissioners may use SEF via an information intermediary as follows:

• by selecting an information intermediary from the drop-down list of intermediaries, with whom they have previously entered into a contract;

• by choosing whether issued and received electronic invoices will be stored in the intermediary’s system or in SEF.

Offices of Section Commissioners may not have more than one information intermediary at the same time, but may change their access method at any time, i.e., switch to direct access to and use of SEF.

Offices of Section Commissioners are not required to use SEF, nor are they required to issue electronic invoices for turnover resulting from Commercial Activities (i.e., retail turnover, as defined by the law governing fiscalisation).