Bosnia Fiscal Representation for Foreign Companies

In Bosnia and Herzegovina, a non-resident that supplies taxable goods or services generally registers through a Bosnia-based tax representative under Article 60 of the VAT law. If the foreign supplier has not appointed one, Article 13(3) can shift the VAT liability for business-recipient services to the recipient instead. That is the core Bosnia fiscal representation rule a foreign supplier needs to settle before invoices go out or local tax assumptions get baked into a contract.

The current VAT-registration threshold used by the Indirect Taxation Authority is BAM 100,000, effective 2023-12-02. Some older English-language official materials still show the previous BAM 50,000 figure, so the source date matters as much as the threshold itself when a finance team is validating Bosnia and Herzegovina fiscal representation rules.

This is a non-resident VAT registration question, not a general Bosnia tax guide. The practical issues are narrower: what kinds of supplies trigger the Article 60 analysis, when a Bosnia VAT representative is the expected path, when Article 13(3) pushes the VAT charge to the business customer, which documents the ITA asks for, and how to handle older English sources that have not caught up with the post-2023 threshold.

What Triggers Article 60 and When the Recipient Accounts for VAT

The Article 60 question usually appears as soon as a foreign company plans to make a taxable supply in Bosnia and Herzegovina. For goods, that can mean goods delivered in BiH, goods installed or assembled there, or other transactions that are treated as a Bosnia supply rather than a simple export into someone else's VAT position. For services, the analysis turns on where the service is treated as supplied and whether the foreign provider has appointed a Bosnia Article 60 tax representative.

Article 13 matters because it identifies who actually pays the VAT once the supply is in scope. The law makes a tax representative liable where a non-resident supplier performs goods or services in BiH, but it also says the recipient of services purchased for business purposes becomes liable if the foreign provider is not based in BiH and has not appointed a representative. In practice, that means Bosnia non-resident VAT registration is not only a filing question. It decides whether the foreign supplier is expected to operate through a representative or whether the Bosnia business customer is pushed into the VAT-paying role for the service it buys.

The quickest decision path is usually this:

• Goods supplied in BiH: start by testing whether the foreign company is making a taxable in-country supply that points toward Article 60 registration through a local representative.
• B2B services: check whether the service is treated as supplied in BiH and whether the foreign provider has appointed a representative. If not, Article 13(3) can move the VAT liability to the recipient.
• Construction or immovable-property services: do not assume the ordinary services rule is the whole answer, because Bosnia has special VAT-liability rules for some property-related construction chains.
• Electronically supplied services: treat digital services as a separate confirmation point. The ITA has issued a dedicated notice for foreign electronic-service providers, so a digital business model should not be analyzed only through the ordinary cross-border-services lens.

That is why the representation question has to be answered before billing logic is finalized. A finance team cannot decide who should charge VAT, who should hold the registration record, or which support file belongs in the transaction pack until it knows which branch of the Bosnia rule set applies.

What a Bosnia Tax Representative Actually Does

A Bosnia tax representative is the locally established party through which the non-resident is registered for VAT under Article 60. That makes the role much more than an address for notices. The representative is the legal bridge between the foreign supplier and the Bosnia VAT system.

Article 60 also makes the taxpayer and the representative jointly and severally liable for the VAT chargeable under the law, and it says the rights and obligations that apply to Bosnia-based taxpayers apply in like manner to the representative. That point is operationally important. A representative is taking exposure alongside the foreign supplier, so the role sits inside the real compliance chain for registration, returns, payments, and recordkeeping. For a controller or outsourced accountant, that is the reason Bosnia VAT representative arrangements need to be settled early rather than treated as an administrative afterthought.

The foreign supplier still owns the underlying commercial activity, the contract facts, and the documents that prove what was supplied and where. The representative's role is different: it anchors the local VAT position and the obligations that flow from it. In practice, the file needs to show who is standing behind the registration, who can support the Bosnia-facing VAT treatment, and which records belong to the supplier versus the representative.

That ownership question should be settled before a finance team standardizes invoice processing workflows, because the right VAT party, registration record, and supporting paperwork depend on whether an Article 60 representative is in place. If that decision is left unresolved, invoice review controls tend to break later, when the tax treatment on the document no longer matches the registration path the transaction should have followed.

Which Documents Go Into an Article 60 Registration Pack

The ITA does not present Article 60 registration as a vague concept. It asks for a specific document pack, and the cleanest way to manage it is to collect those items in the order they usually become available. The ITA Article 60 registration requirements say Article 60 registration requires an agency agreement with a tax attorney, proof of taxable activity in Bosnia and Herzegovina, a domicile-register extract with official translation, identification documents, and a certified specimen signature card for the special transaction account.

Start with the representation paper itself. The agency agreement and power of attorney establish who the Bosnia tax attorney or representative is and who has authority to act. Without that, the rest of the filing pack has no local procedural anchor.

Next, assemble the commercial proof that the foreign company is actually carrying out a taxable activity in BiH. The ITA points to a contract or similar document for this step. That means the file should show the Bosnia-facing supply, not just a corporate intention to enter the market.

After that, pull the foreign corporate evidence together. The domicile-register extract has to come from the home-country register, and the ITA requires an official translation into one of the official languages of BiH. This is often where timelines slip, because legal teams may have the registry extract ready while the certified translation is still pending.

Identification documents for the owner and the responsible person come next. They are straightforward, but they still need to match the rest of the application file cleanly. Names, legal form, and signatory details should be consistent across the register extract, the power of attorney, and the identification documents before the pack is submitted.

The banking item is the one that many foreign suppliers underestimate. The ITA asks for a specimen signature card certified by the commercial bank for the special transaction account, plus the related main-account notification. If the bank setup lags behind the legal paperwork, the registration pack is still incomplete. For that reason, Article 60 preparation works best as a coordinated legal, tax, and banking task rather than a last-minute tax filing exercise.

How to Read the 100,000 KM Threshold When Older Sources Still Show 50,000

The threshold issue is confusing because the conflict is real at the source level. Older English-language official materials, including the long-standing English VAT-law text and the ITA's 2023-02-13 notice for foreign electronic-service providers, still surface the earlier BAM 50,000 registration threshold. Newer ITA material says the threshold increased to BAM 100,000.

The clean way to read that conflict is as a timing problem, not a live policy split. The ITA's 2023-11-29 notice says Article 57(1) was amended, the increase from BAM 50,000 to BAM 100,000 was published in Official Gazette 80/23, and the change took effect on 2023-12-02. So the older 50,000 figure explains what earlier English pages still display, but it is not the current threshold a foreign supplier should rely on now.

For practical compliance work, treat BAM 100,000 as the current Bosnia VAT threshold and treat BAM 50,000 as a legacy figure that may still appear on outdated English pages. The safest habit is to check both the content date and the legal update date whenever a Bosnia source states a threshold without context.

That source-drift point matters because it changes how the article should be used. A reader who sees two numbers is not looking at two current rules. They are usually looking at an older English page that remained online after the law changed, alongside a newer ITA notice that reflects the post-amendment threshold.

Which Bosnia Compliance Question Are You Actually Solving

Foreign suppliers often combine several Bosnia compliance questions into one, and that is where bad assumptions start. Fiscal representation answers who registers and who carries the VAT position. It does not answer what must appear on the invoice. If the open issue is document content, use Bosnia and Herzegovina VAT invoice requirements for the invoice-field and invoice-timing rules.

The same separation matters for sector-specific VAT treatments. If the underlying work involves property, supervision, design, or construction, the representation analysis may overlap with a different liability regime, which is why Bosnia construction VAT special scheme should be checked instead of assuming the ordinary Article 60 path answers everything.

Fiscal representation is also not the same issue as receipt reporting or fiscal devices. Those are separate compliance questions, so a reader dealing with retail-style transaction reporting should review Bosnia and Herzegovina fiscalization requirements rather than treating fiscalization and fiscal representation as interchangeable labels.

Electronically supplied services deserve one more carve-out. The ITA has published a separate notice for foreign providers of digital services, so a software, platform, or other remote-service model should be checked against that guidance as well as the general Bosnia fiscal representation rule.

The fastest way to scope the problem is to verify four points in order:

• Transaction type: goods, general services, construction or property-related services, or electronically supplied services.
• Representation status: whether a Bosnia-based tax representative has already been appointed under Article 60.
• VAT liability holder: whether the foreign supplier or the Bosnia business recipient carries the VAT position for the supply in question.
• Document path: whether the next step is an Article 60 registration pack, an invoice-content review, a construction-VAT analysis, or a fiscalization check.