Ministry of Finance of Republic of Serbia published the Opinion no. 011-00-12/2019-04, dated 01.02.2019., stating that commuting costs are considered non-documented expenses unless the employer provides credible documents as evidence that the employees costs for commuting to and from work have been properly reimbursed (e.g. bill for monthly public transportation ticket, daily ticket, one-way ticket,bill for gasoline if the employee is using his or her personal vehicle, etc.)
According to this Opinion, the employer is to provide each month credible accounting documents, as evidence that the employee has actually used the reimbursement of expenses for that purpose. Otherwise, it is the duty of the employer to consider this non-documented expense and thus taxable as set by Personal Income Tax Law.
According to the article 118 of Labor Law, the employer is to reimburse the costs for commuting to and from work regardless of the fact whether the employee has or has not documented the costs. On the other hand, in order for the employer to require the submission of credible documents, bills/invoices, it is essential to amend the general acts and specify the sanctions in case those provisions are breached.