Grey Book

For the full decade, the Grey Book contains 100 most significant recommendations by businesses, local government and civil society organizations for the regulatory framework improvements and decreasing / eliminating the administrative obstacles to doing business in Serbia. The Government institutions use the Grey Book as one of the main document for preparation of public policy documents and implementation of regulatory reforms, as each of the administrative obstacle is precisely described and argued and the proposal of the solution is provided.

Since it was first published in 2008, the Grey Book has seen 15 editions and presented 321 new recommendations for improving the business environment. Out of this number, 90 have been fully resolved (28%), and 77 partially resolved (24%), meaning that more than half of recommendations have reached the policy makers. 

In 2023, 12 recommendations were implemented, more than 10%, of which seven fully and five partially, which represents a good result, in relative terms, taking into account that over the whole 2022 there was only four months of regulatory activity (not in continuity). 

The new edition of the Grey Book 16 contains 19 new recommendations for the Government of Serbia and 81 adjusted and updated proposals from the previous year. Like in the previous year, in the Grey Book 16 we had focused on the country's commitments in the process of accession to the European Union. We had choosed the 18 recommendations awarded with the "EU badge" in order to point out the reforms that can contribute faster accession of Serbia towards EU. 

The Grey book 16 marked ten priority recommendations for the responsible institutions. These recommendations mostly focus on tax relief for low-income earners, procedures of digitalization, property and planning issues, flexible and seasonal forms of work engagement, higher transparency of non-tax levies and abolishment of para-fiscal charges, and criteria in the are of environment protection, such as public procurement, packaging and wastewater. 

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The first steps

The Grey Book came into existence in 2008 as a result of NALED’s desire to assemble all segments of society and encourage them to engage and contribute to the common goal – building a better business environment by eliminating redundant and obsolete administrative procedures. No initiative before or after the Grey Book had dealt systematically with the administrative and practical problems faced by businesses on a daily basis, which led to Grey Book being accepted by institutions as a strategic document in planning policy reforms.

Late in May 2008 the public was introduced to the „Out of the Maze“ campaign NALED initiated together with USAID and B92 TV station. Citizens and businesses were invited to nominate complicated procedures and propose models of improvement. During June, NALED received as much as 245 justified proposals, 55 of which earned their place in the first issue of the Grey Book. Three citizens were prized for their proposals for improving the procedures of TIN assignment, construction permitting and tax filling.

Key Results

The Grey Book is responsible for elimination of some of the proverbial bureaucratic barriers. Based on NALED’s initiative, to name a few examples, the wage tax and social security contributions are now paid to a single account instead of 12 different accounts, the institutions no longer require that an excerpt from public records is not older than six months, the employment booklets are no longer used, the health insurance card are verified automatically, and the construction permitting procedures have been significantly improved. New businesses obtain a tax identification number (TIN) in BRA in a much easier fashion and if they are micro or small enterprises they are exempted from the signage fee. Pregnant women and new mothers no longer need to collect dozens of different original documents and certified copies to exercise the right to allowance during pregnancy and maternity leave, new employees are now registered electronically via online portal of the central registry of compulsory social insurance (CRCSI) and businesses do not need to provide a seal to open a bank account and conduct a payments. A unique place for the registration of property in the cadastre through the eCounter was established, which decreased the number of institutions that buyers need to go, while the procedure of property tax claim for citizens and businesses has been simplified. The implementation of the new Law on Fiscalization and the Law on Electronic Invoicing (the two long-standing recommendations of the Grey Book) will have a positive effect on reducing the grey economy, but also on the work of businesses. The whole procedure of buying and selling the used motor vehicles among the citizens has been relieved and simplified for the calculation and payments of the tax on the transfer of absolute rights, electronic payments of fees and levies for the services provided by the Ministry of Interior, without providing a proof of payments was enabled, the Central Register of Real Owners in food manufacturing has been digitalized, all of which represents the realization of the initiatives and policy reforms proposed by NALED in the previous years. In the previous five years the tax burden on net wages has been decreased by 2 percentage points (from 63% to 61%).   

Reforms to long on hold
In addition to the reforms implemented, there are several proposals that have not been resolved in previous years. One such recommendation is to establish a public electronic register of non-tax duties and abolish parafiscals. This list also includes recommendations related to shortening the deadline for the VAT refunds, the introduction of cashless payment of all fees and charges without the obligation to prove payment for all procedures, the introduction of unified collection of tax obligations for entrepreneurs (one account instead of four), the acceleration and digitization of the legalization procedure and the abolition of the fee for conversion of rights of use into the right of ownership.


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