When Should You Register for VAT in Bulgaria?
Many new business owners assume that VAT becomes relevant only after the company reaches a certain level of sales. In practice, turnover is only one part of the VAT registration rules.
A company with modest revenue may still need VAT registration in Bulgaria because it provides services to an EU business, buys services from a foreign supplier or acquires goods from another EU Member State.
That is why VAT planning should start with the transactions, not only with the annual sales figure. Before issuing your first international invoice or paying for a foreign business service, ask what VAT rules apply to that specific transaction. 📌
1. Registration After Reaching the Bulgarian Turnover Threshold
From 1 January 2026, a taxable person established in Bulgaria generally becomes subject to mandatory VAT registration when its annual turnover in the country exceeds EUR 51,130. The business monitors this turnover for the calendar year. Once it exceeds the national threshold, the application must generally reach the National Revenue Agency within seven days.
This change makes regular monitoring especially important for businesses that grow quickly. Waiting until the accountant closes the year may leave too little time to react.
What Should You Monitor?
Keep an eye on:
- your annual turnover in Bulgaria;
- the dates when supplies take place;
- advance payments where relevant;
- new types of transactions;
- sales to customers outside Bulgaria;
- other VAT registration grounds that do not depend on turnover.
A business can therefore face a registration obligation before it expects one from sales alone.
2. Services Supplied to Business Clients in Other EU Countries
A Bulgarian company or self-employed professional may need registration under Article 97a of the Bulgarian VAT Act when it supplies certain services to a taxable customer in another EU Member State and the customer accounts for the VAT there.
The rule can apply before the business reaches the general turnover threshold. The National Revenue Agency states that the application must be filed no later than seven days before the date on which VAT for the relevant supply becomes chargeable.
This often matters for businesses that provide:
- consulting;
- IT and software development;
- marketing services;
- design;
- professional online services;
- other cross-border B2B services.
Do not assume that every service to a foreign customer follows the same rule. The place-of-supply rules and the status of the customer still matter.
For EU business clients, you should also verify the customer’s VAT number through VIES when the tax treatment relies on its EU VAT status. VIES checks whether a business is registered for cross-border EU trade, and the European Commission recommends keeping evidence of the validation.
3. Services Received From Foreign Suppliers
Article 97a can also affect a Bulgarian business that receives taxable services from a supplier established abroad when Bulgarian VAT becomes payable by the recipient.
This situation appears surprisingly early for many start-ups. A new company may not have issued a single sales invoice but may already pay for foreign advertising, software or cloud services.
Typical examples include:
- online advertising platforms;
- foreign SaaS subscriptions;
- hosting and cloud services;
- platform fees;
- foreign consulting services.
The registration deadline can arise before VAT on the first relevant service becomes chargeable.
One important detail often gets overlooked: registration only under Article 97a does not provide the same input VAT deduction rights as registration under the general VAT regime. The National Revenue Agency expressly states that persons registered only under Article 97a do not have the general right to deduct input VAT.
4. Purchases of Goods From Other EU Member States
Businesses that buy goods from suppliers in other EU countries should monitor a different threshold.
For a taxable person or certain non-taxable legal persons that are not registered under the general VAT regime, mandatory registration for taxable intra-Community acquisitions arises when the total value for the current calendar year exceeds EUR 10,000.
The application must reach the tax authorities no later than seven days before the transaction that causes the threshold to be exceeded.
This rule focuses on qualifying purchases of goods, so looking only at sales revenue will not protect the business from missing the deadline.
5. Foreign Companies With Goods or Sales in Bulgaria
A foreign company can also create Bulgarian VAT obligations even when its head office remains abroad.
The analysis becomes important when the business moves stock to Bulgaria, carries out taxable supplies in Bulgaria or keeps goods here before selling them.
From 2026, EU-established businesses also need to consider the EU small-enterprise VAT scheme. An EU business that does not apply the relevant exemption in Bulgaria may need Bulgarian VAT registration before its first taxable supply with a place of supply in Bulgaria. Businesses established outside the EU generally cannot use the EU small-enterprise scheme and may also face registration before the first relevant taxable supply.
Simply renting warehouse space does not answer the VAT question by itself. You need to trace:
- where the goods come from;
- when they enter Bulgaria;
- who owns them;
- where they are located at the time of sale;
- who buys them;
- whether another special VAT regime applies.
Quick VAT Registration Check
| Situation | What to Review | Main Risk |
|---|---|---|
| Bulgarian annual turnover | EUR 51,130 threshold and exact date exceeded | Late general VAT registration |
| B2B services to EU clients | Customer status, place of supply, Article 97a | Issuing the first invoice too early |
| Foreign services received | Supplier location and reverse-charge rules | Missing Article 97a registration |
| Goods bought from the EU | EUR 10,000 acquisition threshold | Monitoring sales but not purchases |
| Foreign stock in Bulgaria | Movement, storage and local supplies | Assuming warehouse use has no VAT effect |
| Voluntary registration | Business model and expected purchases | Registering without reviewing consequences |
6. Voluntary VAT Registration
A Bulgarian taxable person may also choose voluntary registration before mandatory registration becomes necessary. The National Revenue Agency confirms that an eligible business may apply under Article 100 and that there is no general application deadline for voluntary registration.
Voluntary registration may make commercial sense when a business works mainly with VAT-registered customers or expects significant purchases connected with taxable business activity.
However, the decision deserves a proper review. VAT registration creates continuing reporting and compliance obligations. It should therefore form part of the business plan rather than serve as an automatic choice.
Check VAT Before the Transaction, Not After It
A useful VAT review asks more than one question. Where is the customer? Is the customer a business? Where is the supplier? Are you buying goods or services? Where do the goods move? What payment or supply will happen first?
These details often determine the registration date more accurately than turnover alone.
Not sure which VAT registration rule applies to your next transaction? T&G Consulting can review your business model and cross-border transactions and help you identify the correct VAT registration route before the deadline becomes a problem.
The safest approach is to check VAT before the first invoice, foreign subscription, EU purchase or movement of stock. A business that understands the VAT position early can issue documents correctly, plan its reporting and avoid having to reconstruct transactions months later. 🙂
For useful and interesting information, visit our partners’ channel.
This article provides general information only and does not constitute individual tax, accounting or legal advice. VAT treatment depends on the facts of each transaction and should be reviewed individually.