Understanding Bosnia and Herzegovina VAT Registration Triggers and Thresholds

How Bosnia and Herzegovina VAT registration triggers work

Bosnia and Herzegovina asks one question of everyone: are your taxable sales in the country above BAM 100,000? Presence in the country does not change that question, which makes Bosnia and Herzegovina simpler than many jurisdictions and different from most US states. Kintsugi tracks your position against the threshold and tells you when you cross it.

• The threshold is BAM 100,000 of taxable sales, roughly EUR 51,000

• It is tested on the previous calendar year, or on the current year if you expect to exceed it

• A branch, an office, staff, or a warehouse in the country does not force day-one registration. The threshold still applies

• A non-resident business selling only to business customers has no registration duty, whatever the volume

• Apply by the 20th of the month after you cross, and the ITA decides within 15 days

• You charge VAT from the effective date on your registration certificate, not from the day you crossed

The Threshold

The threshold was BAM 50,000 until 2 December 2023, when it doubled to BAM 100,000. Older guidance still quoting BAM 50,000 is out of date.

What Counts Toward The Threshold

Counts:

• Taxable sales to businesses and to consumers

• Sales of goods and sales of services

• Zero-rated supplies, such as exports

• Sales made through a marketplace or platform

• Sales to related parties

Does not count:

• Exempt supplies, meaning the ones with no input VAT recovery

• Refunded sales, which come off at the date of the credit note

• Imports where your customer is the importer of record, because the place of supply is outside the country

A non-resident business selling only to business customers is not required to register at all, whatever the total. That carve-out applies to services and digital supplies. Note the distinction: business sales still count toward the figure if you have a mix of business and consumer sales, but a business-only seller has no duty to register.

The Forward-Looking Test

Bosnia and Herzegovina does not wait for you to actually cross. The law reaches businesses whose turnover is likely to exceed the threshold, which means a plan or a trajectory can create the obligation before the revenue arrives.

Two practical consequences:

• If you are launching in the country and already expect to be above BAM 100,000, you apply no later than 8 days before you start trading

• If you cross mid-year, you do not wait for 1 January

Deadlines Once You Cross

Registering Voluntarily

You can register below the threshold. Two things to weigh first:

• Registering is the only way to recover Bosnia and Herzegovina input VAT, including import VAT you have paid at the border

• A voluntary registration commits you for a minimum of 60 months

If you want the input VAT recovery sooner than the threshold would give it to you, voluntary registration is the route. If you are unsure, raise it with us before you submit, because the 60-month commitment is not something you can unwind at will.

What Kintsugi Monitors

Kintsugi tracks three kinds of exposure in Bosnia and Herzegovina:

• Economic exposure, meaning your taxable sales against BAM 100,000

• Physical exposure, meaning a branch, office, staff, warehouse, or other fixed presence in the country

• Collected-tax exposure, meaning tax you have already collected there without meeting either of the above

Physical exposure is reported for your awareness. It does not by itself mean you have to register, because Bosnia and Herzegovina keeps the threshold test in place regardless of presence.

What This Does Not Cover

• Registration and filing for businesses with a physical presence in Bosnia and Herzegovina. Kintsugi monitors that exposure and tells you when it exists. Registering and filing for a locally established business is handled outside Kintsugi.

• Goods sold into the country. These are taxed as imports at the border and are not part of Kintsugi's calculation, so if you sell goods your real threshold position may differ from what Kintsugi shows.

• Penalties for late registration. Kintsugi does not calculate them.

• Back filings for periods before your registration date. Raise these with us so they can be assessed separately.

• How to submit the registration. See Request a Bosnia and Herzegovina VAT Registration in Kintsugi.

This article is general information about how Kintsugi works, not tax advice for your specific situation.

FAQs

Q: I have an employee in Sarajevo. Do I have to register immediately?

A: No. Unlike many jurisdictions, Bosnia and Herzegovina keeps the BAM 100,000 test in place even when you have people or premises in the country. Kintsugi flags the presence so you know it is there, and the threshold still decides the obligation.

Q: Do my sales to Bosnian businesses count toward the threshold?

A: Yes, if you also sell to consumers there. If every Bosnia and Herzegovina sale you make is to a business, you have no registration duty regardless of the total.

Q: I crossed BAM 100,000 in March. When do I start charging VAT?

A: Apply by 20 April. You start charging from the effective date on your registration certificate, not from the date you crossed. Do not add VAT to invoices before that date.

Q: Does inventory in a Bosnian warehouse trigger registration?

A: Storage on its own does not, provided no people or systems there are used to complete sales. If they are, the usual BAM 100,000 test applies.

Q: What is BAM 100,000 in dollars?

A: The mark is pegged to the euro, not the dollar, so the euro figure is stable at about EUR 51,000 while the dollar figure moves. Kintsugi tracks your position in BAM.

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