Goods and services in the construction sector, within the meaning of Article 10, paragraph 2, item 3) of the Law, are goods and services whose supply is performed in accordance with Article 4, paragraph 1 and paragraph 3, item 6), and Article 5, paragraph 1 and paragraph 3, item 3) of the Law, within the scope of activities from the following groups of the Classification of Activities prescribed by the Regulation on the Classification of Activities (“Official Gazette of the RS”, No. 54/10), in a value exceeding RSD 500,000, excluding VAT:
41.20 Construction of residential and non-residential buildings
42.11 Construction of roads and motorways
42.12 Construction of railways and underground railways
42.13 Construction of bridges and tunnels
42.21 Construction of utility pipelines
42.22 Construction of power and telecommunication lines
42.91 Construction of hydraulic engineering structures
42.99 Construction of other civil engineering projects n.e.c.
43.11 Demolition
43.12 Site preparation
43.21 Electrical installation
43.22 Plumbing, heat and air-conditioning installation
43.29 Other construction installation works
43.31 Plastering
43.32 Joinery installation
43.33 Floor and wall covering
43.34 Painting and glazing
43.91 Roofing activities
43.99 Other specialised construction activities n.e.c.
When a VAT taxpayer performs the activities referred to above, regardless of whether it is formally registered for those activities, on the customer’s order and using its own materials, provided that those materials are not merely accessories or minor auxiliary materials, the taxpayer is deemed to supply construction goods within the meaning of Article 10, paragraph 2, item 3) of the Law.
When the taxpayer performs the same activities using the customer’s materials, the taxpayer is deemed to provide construction services within the meaning of Article 10, paragraph 2, item 3) of the Law.
The value of the supply is determined on the date of the supply. A subsequent increase or decrease in the value does not affect whether the supply is considered a supply of construction goods and services for the purposes of Article 10. The value threshold also applies to partial deliveries of goods and partial services.
Article 25
By way of exception, regardless of value, the following are not considered goods and services in the construction sector within the meaning of Article 10, paragraph 2, item 3) of the Law:
repair of equipment forming an integral part of a building, including repairs of parts of that equipment;
repair of installations and parts of installations referred to in Article 24, paragraph 1, item 12) of the Rulebook;
supply with installation, or installation, of kitchen and bathroom elements (for example sinks, worktops, wall units, shower cabins, washbasins, etc.), as well as wardrobes, shelves, bookcases and other furniture in buildings;
supply with installation, or installation, of heating or cooling appliances;
supply with installation, or installation, of irrigation systems and their components;
supply of goods and provision of services relating to landscaping, including landscaping within or on buildings.
Heating or cooling appliances are individual goods such as air conditioners or refrigerated display cases, and not complete heating or cooling systems such as central air-conditioning or central heating systems.
Irrigation systems are sets of goods forming such systems, in particular hoses, sprinklers, valves, pumps and filters.
Article 26
If a supply of construction goods or services includes an ancillary supply of other goods or services, it is deemed that only a supply of construction goods or services has been made. Conversely, if the principal supply is not considered a construction supply, but includes ancillary elements that would otherwise fall within construction, the entire transaction is treated as a non-construction supply.
To learn more about VAT exemptions and Article 10 of the Serbian VAT Law, contact us at or by phone at 011 6169530.