In the e-consultation process, 140 proposals, remarks and comments were received on the Draft Rulebook on the Amendment to the Rulebook on the Application of the Value Added Tax (VAT) Law, which will specify the rules related to the return of VAT on the first property purchased.
It has been confirmed for “Nezavisne novine” from the Administration for Indirect Taxation (ITA) of BiH, which published this draft on the e-consultation website on September 11, and interested parties had 15 days to access the document and submit their comments and suggestions on that document.
-140 comments were received on the draft rulebook on VAT
– ITA BiH completes its review by October 23
– The report goes to the Board of Directors by the end of the week
-VAT refund limited by the average price of apartments in Bosnia and Herzegovina
-Buyers in larger cities receive a smaller VAT refund
– All received remarks were considered and contained in the Report on the conducted consultations, which contains more than 100 pages. In addition to these comments, the comments received from the entity bodies that were submitted to the ITA outside the public consultation platform were also considered – the ITA BiH told “Nezavisne novine”.
They claim that the review will be fully completed by October 23 and this will conclude the report.
– That report, together with the text of the draft rulebook, will be sent to the Management Board of the ITA by the end of this week – said the ITA of BiH.
It is not yet known when the Board of Directors of the ITA of BiH will meet. The date, as confirmed to us, has not yet been defined.
– The objections are under consideration and work is being done to amend and supplement the proposed rulebook. The date for the meeting of the Board of Directors of the ITA has not yet been set – said the interlocutor of “Nezavisne novina”.
Associations for consumer protection believe that this benefit has been waiting too long.
– We have a classic, inconsistent system. It is very difficult for citizens to assess who is responsible for all this. I think that certain authorities are not interested in starting the implementation of this by-law. And I also have a bit of a grudge against citizens who have no major objections institutionally – Snežana Šešlija, president of the Citizens’ Association “Tolerance against Diversity” (ToPeeR) from Doboj, told “Nezavisne novine”.
Let us remind you that after the draft of the regulations was published before the e-consultation period, it turned out that buyers of first real estate in Banja Luka, Sarajevo and other major cities will not be able to count on a refund of the entire VAT they paid.
Namely, in that document it was stated that the maximum price at which a VAT refund can be granted is actually the average price of an apartment with VAT in BiH, which was published by the Agency for Statistics of BiH in the last quarterly report.
In practice, this means that the average price will also be affected by the prices of apartments in extremely small areas, where real estate is much, even many times cheaper than in larger cities.
Or to be more precise – the average price of new apartments sold per square meter in the second quarter of 2025 in BiH was 3,147 KM, and in Banja Luka 3,649 marks.
Therefore, those who bought an apartment in Banja Luka in April, and paid 530.20 KM VAT per square meter, will be refunded 456.40 KM per square meter.
And that’s not all: the draft rulebook foresees a VAT refund in the maximum amount of 24,557.74 KM, which means that buyers of more comfortable apartments, in larger cities, will not be able to count on the full amount of VAT even on that basis.
