VAT registration in Bulgaria for companies and individuals. Deregistration (2025)

Registration and deregistration of a company under VAT in Bulgaria is a key process that affects both newly created companies and established businesses operating in the domestic and international markets. The VAT regime provides certain advantages, but it also imposes additional administrative obligations that must be implemented correctly in order to avoid penalties and adverse consequences. Registration can be mandatory or voluntary, with the VAT registration threshold in 2025 and related requirements being important factors for any company that makes taxable supplies. Deregistration, in turn, also has its consequences, which require careful planning and compliance with legal procedures.

Our clients often ask us questions such as:

• What is the VAT registration threshold in 2025 and how is the taxable turnover for registration calculated?
• What documents are needed for VAT registration and what does the application for VAT registration contain?
• How is VAT registration in the NRA carried out and how can I check the status of my registration?
• What is the difference between mandatory and voluntary VAT registration, and when is it more profitable to register voluntarily?
• What should I do if I miss the deadline for mandatory VAT registration?
• What are the conditions for registration under Art. 97a of the ZVAT and what documents are required?
• What is a taxable turnover statement for VAT registration and where can I find a form to fill out?
• What is the amount of VAT in Bulgaria and how does it affect the pricing and reporting of my company?
• What are the consequences of VAT deregistration and what obligations arise upon termination of registration?

In this article, we will examine in detail all aspects of VAT registration and deregistration — from the legal requirements and necessary documents to the important deadlines and practical steps that businesses need to take. Consulting company “Elan Consulting” provides professional assistance for registration, deregistration and tax planning, serving clients in Sofia, Burgas, Pomorie, Karnobat, Sunny Beach, Aytos, Nessebar, Sozopol, Primorsko and the whole of Bulgaria.

What is VAT registration of a company in Bulgaria?

VAT registration in Bulgaria is regulated in Chapter Nine of the Value Added Tax Act (VAT) and is a process by which a taxable person enters the special register maintained by the National Revenue Agency (NRA). Pursuant to Article 94 (1) of the VAT Act, the NRA establishes and maintains this register as part of the register under Article 80, paragraph 1 of the Tax and Insurance Procedure Code (DOPC). Upon entry in this register, the person receives an identification number for VAT purposes, in front of which the sign “BG” is affixed (Art. 94 (2) of the ZVAT). Registration can be compulsory or optional (Art. 94, para. 3 of the GDPR), and the procedure is regulated in detail in the law.

Pursuant to Article 95 (1) of the VAT Act, registration under this Act is subject to any taxable person who is established in the territory of the country and carries out taxable supplies of goods or services under Article 12 of the VAT Act. In addition, Art. 95 (2) of the VAT Act stipulates that registration is also mandatory for taxable persons who are not established in Bulgaria, but carry out taxable supplies of goods or services on the territory of the country, except in cases where the tax is payable by the recipient.

The law defines “taxable supply” in Article 12, paragraph 1 of the VAT, according to which:
'Taxable supply is any supply of goods or services within the meaning of Articles 6 and 9, when it is made by a taxable person under this Act and has its place of performance in the territory of the country, as well as the supply taxable at zero rate, except in cases where this law provides otherwise. '
Therefore, in order for there to be a basis for registration, the supplies that the person carries out must fall within the scope of Article 12 of the ZVAT.

Supplies of goods and services falling within the scope of VAT registration

Supplies of goods

According to Art. 6, para. 1 of the GDPR, the supply of goods is:
“The transfer of the right of ownership or other right in rem over the goods, as well as any other right to dispose of the goods as owner.”

In addition, Article 6 (2) of the VAT Act specifies that the following shall also be considered as a supply of goods:

1. The transfer of the right of ownership of goods at the request of a state or local authority or on the basis of a law against compensation.
2. The provision of goods under a contract that provides for the transfer of ownership under a deferred condition or term.
3. The provision of goods under a lease agreement, in which the option of transfer of ownership is agreed.
4. The actual provision of goods to a person acting on his own behalf and on someone else's account.

Supply of services

According to Article 9 (1) of the VAT Act, the following shall be deemed to be a supply of a service:
“Any performance of service.”

In addition, Art. 9, para. 2 of the VAT Act specifies that the following are accepted as a supply of service:

1. The sale or transfer of rights to intangible property.
2. The assumption of an obligation not to perform actions or not to exercise rights.
3. Physical and intellectual labor, including construction, processing, installation of a material asset.
4. Repair of a leased asset or improvement of an asset made available for use.

If a taxable person carries out supplies of goods or services that fall into the above categories and have a place of performance in Bulgaria, he should register for VAT in compliance with the legal conditions.

Consequences of VAT registration

After registration in the register, the taxable person receives a certificate of registration under VAT and VAT number (VAT number), in front of which stands the code “BG” (Art. 94, para. 2 of the ZVAT). This means that the person is obliged to:

• To charge VAT on its taxable supplies;
• To draw up invoices and other documents in accordance with the requirements of the law;
• To submit monthly reports-declarations and logs for purchases and sales to the NRA;
• Report your tax obligations in a timely manner to avoid penalties.

Registered persons may deduct a tax credit for acquired goods and services used in their economic activity if they meet the conditions of Art. 71 of the VAT Act.

Lack of supply within the meaning of the law

Not every transfer of ownership constitutes a taxable supply. Article 10, paragraph 1 of the VAT Act states that there is no supply of goods or services in the case of:

1. Transformation of a commercial company under the Commercial Law.
2. Transfer of an enterprise in accordance with Art. 15 or 60 of the Commercial Law.
3. Non-monetary contribution to a commercial company.
4. Transformation of budgetary organizations or state enterprises with legal succession.

In these cases, VAT is not charged and the person receiving the goods or services inherits all rights and obligations, including the right to use a tax credit.

When is VAT registration mandatory?

VAT registration in Bulgaria is mandatory in certain cases regulated in Art. 96 — 97c of the Value Added Tax Act (VAT). It is mainly imposed on taxable persons who reach a certain taxable turnover, as well as on those who carry out specific supplies within the territory of the country or within the European Union.

Mandatory registration due to reaching taxable turnover

Pursuant to Article 96 (1) of the VAT Act, any taxable person established in the territory of Bulgaria who for a period not exceeding the last 12 consecutive months has realized a taxable turnover of EUR 84 874 (or the equivalent in BGN) is obliged to submit an application for VAT registration. This application must be submitted within 7 days of the expiration of the tax period during which the turnover was reached.

In the event that the turnover is reached for a period not exceeding two consecutive months, including the current one, the person is obliged to submit the application within 7 days from the date on which the turnover was reached (Art. 96, para. 1 of the VAT Act).

What is taxable turnover?

The taxable turnover is formed from the amount of the tax bases of the following supplies made by the person (Art. 96, para. 2 of the ZVAT):

1. Taxable supplies — all supplies of goods and services for which VAT is charged, including those at zero rate.
2. Supplies of financial services — referred to in Article 46 of the ZVAT.
3. Supplies of insurance services — according to Art. 47 of the ZVAT.

Important:

• The taxable turnover does not include supplies under items 2 and 3 if they are not related to the main activity of the person (Art. 96, para. 3 of the VAT Act).
• Deliveries of fixed assets used in the person's activities are not included.
• The supplies for which the tax is payable by the recipient under Article 82 (2) and (3) of the VAT Act are not included.

In addition, advance payments received for future taxable supplies are included in the taxable turnover, except in cases where the taxable event has not yet occurred (Article 96 (4) of the VAT Act).

Mandatory registration, regardless of turnover

Some individuals are required to register for VAT, regardless of their turnover. This applies to:

1. Persons supplying goods with assembly and installation

Pursuant to Article 97 (1) of the VAT Act, any person established in another Member State who is not established in the territory of Bulgaria but carries out taxable supplies of goods which are installed or installed in Bulgaria is subject to compulsory registration.

• Deadline for filing an application: No later than 7 days before the date of occurrence of the tax event (Art. 97, para. 2 of the VAT Act).
• Exception: Registration is not required if the recipient of the supply is a VAT registered person (Art. 97, para. 3 of the ZVAT).

2. Persons receiving or providing services for which the tax is chargeable to the recipient

According to Art. 97a, para. 1 of the GDPR, registration is mandatory for every taxable person in Bulgaria who receives services with a place of performance in Bulgaria for which the tax is payable by the recipient (Art. 82, para. 2 of the GDPR).

Furthermore, pursuant to Article 97a (2) of the VAT Act, registration is compulsory for any person established in Bulgaria who provides services with a place of performance in another Member State, where the recipient is a taxable person or a non-taxable legal person registered for VAT in that Member State.

• Deadline for submitting an application: No later than 7 days before the date on which the delivery tax becomes chargeable (Art. 97a, para. 4 of the VAT Act).

3. Persons carrying out intra-Community distance sales or services electronically

According to Article 97c of the GDPR, registration is compulsory for taxable persons who are not registered in Bulgaria but who carry out intra-Community distance sales, telecommunications services, radio and television broadcasting services or services electronically, with a place of performance in another Member State.

• Application deadline: 7 days after issuing a VAT number in another Member State.

Additional provisions and restrictions

According to Art. 96, para. 8 of the GDPR, even if a person meets the criteria for compulsory registration, the NRA may refuse registration if his registration was previously terminated or refused on the basis of Art. 176 of the ZVDA.

Also, if two or more related persons or persons acting in concert carry out a uniform activity in the same place of business, the turnover of the previous persons shall be included in the taxable turnover of the new person (Article 96 (10) of the VAT Code).

An exception to this rule exists if there has been a break between the two activities for more than one month (Art. 96, para. 11 of the GDPR).

Do I have to register for VAT on intra-Community acquisitions?

An intra-Community acquisition (IP) of goods is the purchase of goods by a taxable person registered for VAT purposes in another Member State of the European Union (EU) when the goods are transported from one Member State to another. The Law on Value Added Tax (VAT) regulates the obligation to register for VAT under VAT in Article 99 of the ZVAT.

Which persons are subject to mandatory registration with the GPO?

Pursuant to Article 99 (1) of the VAT Act, the obligation to register for VAT arises for:

• Non-taxable legal entities;
• Taxable persons who are not registered under the VAT Act on the basis of:
  • Art. 96 (mandatory registration due to turnover);
  • Art. 97 (registration upon delivery of goods with assembly);
  • Art. 100, para. 1 (voluntary registration);
  • Art. 102 (mandatory registration for the supply of electronic services in the EU).

Such persons are subject to registration if they carry out intra-Community acquisitions of goods, unless they fall within the exceptions provided for by law.

When does the obligation to register with the GPO arise?

The registration obligation is determined by the threshold for intra-Community acquisitions. According to Art. 99, para. 2 of the ZVAT, persons who carry out VOD are subject to registration only if the total value of the acquisitions for the current calendar year exceeds 10,000 euros (or the equivalent in BGN).

In the event that the value of the VAT exceeds 10,000 euros, according to Article 99, paragraph 3 of the VAT, the person is obliged to submit an application for registration no later than 7 days before the date of occurrence of the tax event for the acquisition, by which this threshold is exceeded. The tax becomes due for the transaction by which this threshold is crossed.

How is the total value of the CAP calculated?

Pursuant to Article 99 (4) of the VAT Code, the value of intra-Community acquisitions is calculated as the sum of the taxable VAT excluding VAT due or paid in the Member State from which the goods are transported or dispatched. Exceptions are:

• Acquisition of new means of transport;
• Acquisition of excise goods — these goods are taxed under a special regime, regardless of the threshold of 10,000 euros.

Exceptions to the obligation to register in the case of a GPO

Not all persons who carry out VAT are required to register for VAT. According to Art. 99, para. 5 of the VAT Act, the obligation to register with the GPO does not apply to:

1. Persons under Art. 168 of the ZVAT who acquire new vehicles.
2. Persons under Art. 2, item 4 of the GDPR.

Special cases of compulsory registration in the case of a VAT

In addition to the standard rules, there are specific situations in which a person must register for VAT on intra-Community acquisitions, regardless of the value of the transaction.

Taxable persons from other Member States carrying out VAT in Bulgaria

Pursuant to Article 99 (7) of the VAT Act, any taxable person established in another Member State who carries out intra-Community acquisition of goods on the territory of Bulgaria under Article 15a, paragraph 6 or Article 65a of the GDPR is subject to compulsory registration.

• Deadline for registration: 7 days before the date of occurrence of the tax event under Art. 15a, para. 6 or Art. 65a (Art. 99, para. 8 of the GDPR).

What happens after registration with the CAP?

A person who registers on the basis of Art. 99 of the GDPR has the following obligations:

• To charge and report VAT on VAT by self-charging the tax through the reverse charging mechanism.
• To file monthly VAT returns in which to declare intra-Community acquisitions.
• To report the VAT due to the NRA, calculating the tax base and the amount of tax due on each transaction.

Transition from registration under the GTC to another registration under the VAT

If a person registered for intra-Community acquisitions subsequently reaches a turnover for compulsory registration under Art. 96 or Art. 97, he or she is registered in accordance with the procedure of compulsory registration (Art. 99, para. 6 of the GDPR).

If he wishes to continue his activity as a VAT registered person, he may submit an application for voluntary registration under Article 100, paragraph 1 of the VAT Act.

Can I register a company voluntarily for VAT in Bulgaria? What are the advantages of doing this and when does it make sense to do it?

VAT registration in Bulgaria can be mandatory or voluntary. While compulsory registration takes place upon reaching a certain taxable turnover or under other legally determined conditions, voluntary registration is the choice of taxable persons. Art. 100 of the Value Added Tax Act (VAT) regulates the possibility of voluntary registration, giving companies the right to register even if they have not reached the threshold for mandatory registration.

Which persons can register voluntarily for VAT?

According to Art. 100, para. 1, of the VAT Code, any taxable person who does not meet the conditions for compulsory registration under Art. 96, para. 1, may submit an application for registration at his own discretion. This means that even if the company has not reached a taxable turnover of 84 874 euros (for 12 months), it has the right to request VAT registration.

Furthermore, pursuant to Article 100 (2) of the VAT Act, taxable and non-taxable legal persons who do not meet the conditions for compulsory registration under Article 99 (1) may also apply for voluntary registration for intra-Community acquisition.

When can voluntary registration not take place?

The law introduces a restriction on voluntary registration in Art. 100, para. 4 of the GDPR. A company cannot register voluntarily if:

• The NRA terminated or refused registration of the company on the basis of Art. 176 of the VAT Act (e.g. if the company did not file returns, did not fulfill its tax obligations or abused the VAT regime).
• Not 24 months have passed from the date of deregistration or refusal of registration.

What are the advantages of voluntary VAT registration?

Ability to deduct a tax credit

One of the biggest advantages of VAT registration is the right to deduct a tax credit. This means that the firm can deduct the VAT paid on goods and services used for its economic activity. For example:

• If the company purchases equipment, materials or services for which VAT has been charged, it can recover this VAT through the tax credit.
• This is especially useful for start-up businesses that make significant investment costs at the initial stage.

Enhancing confidence and competitiveness

VAT registration can make the company more attractive to customers and business partners.

• Large companies and international partners often prefer to work with VAT-registered companies, as this allows them to recover VAT from invoices.
• In certain sectors, such as wholesale, construction and international services, working with VAT unregistered companies can create difficulties for business partnerships.

Easy entry into the international market

If the company plans to work with clients in the European Union, VAT registration may be mandatory or highly recommended.

• Intra-Community supplies of goods and services generally require a VAT number.
• If a company supplies services in the EU and wants to avoid the obligation to register in other Member States, it can use the OSS (One Stop Shop) regime, which requires VAT registration.

Possibility of reverse charging of VAT

If the company uses subcontractors operating under the VAT regime, they can invoice it without charging VAT on reverse charge. This reduces costs and improves cash flow.

When does it make sense to make a voluntary VAT registration?

When the company has significant expenses with accrued VAT

If the company plans to purchase equipment, materials or assets with high VAT, its registration allows it to recover the tax paid. This can reduce costs and improve its financial position.

When clients and partners prefer to work with VAT-registered companies

In certain business sectors, companies that are not registered for VAT are perceived as less reliable.

• For example, if a company operates in the B2B segment (business to business), its customers may prefer to receive invoices with VAT charged, which they can deduct.
• In construction, wholesale trade and international supplies, VAT registration is almost mandatory for competitiveness.

When the company exports goods or services to the EU

• VAT registration facilitates intra-Community trade and saves the need for additional registrations in other countries.
• If the company carries out intra-Community supplies of goods, it can invoice at a zero rate of VAT, but for this it must be registered for VAT.

When the company works with VAT subcontractors

If a company frequently uses services or materials from VAT-registered counterparties, voluntary registration allows it to deduct the tax on these costs, which improves its profitability.

How do I apply for voluntary registration?

The company can submit an application for VAT registration:

• Through the NRA, once it is registered in the Commercial Register.
• At the initial registration of the company, directly at the Registry Agency (Art. 100, para. 5 of the GDPR).

The NRA conducts an audit of the company before approving the registration, and may require additional documents.

What is the VAT registration procedure in Bulgaria? Are there procedural differences between voluntary and compulsory registration?

VAT registration in Bulgaria is carried out by filing an application with the National Revenue Agency (NRA), and the procedure is regulated in Articles 101 — 105 of the Value Added Tax Act (VAT). Registration can be mandatory or voluntary, but the procedural steps are similar regardless of the reason for registration.

According to Art. 101, para. 1 of the ZDDS, registration is carried out by submitting an application for registration in a form to the competent territorial directorate of the NRA. Persons who wish to register voluntarily at the time of incorporation may apply for registration directly at the Registry Agency upon submission of the documents for initial registration of the company (Art. 100, para. 5 of the VAT Act).

The application can be submitted in several ways, depending on the type of person, according to Art. 101, para. 2 of the GDPR. If the application is submitted by an individual or sole trader, it must be submitted in person. Legal entities submit the application through a legal representative, which may be the manager of the company or another person with representative power by law or contract. It is possible that the application can also be submitted by an authorized person, but the power of attorney must be notarized. Lawyers can also submit applications for registration by written power of attorney, which must meet the requirements of the Law on Advocacy.

The application for registration can also be submitted electronically, in accordance with Art. 101, para. 3 of the GDPR, and for this purpose the person must have an electronic signature. When submitting the application, the grounds for registration must be indicated, attaching documents specified in the Regulations on the Application of the VAT (Art. 101, para. 4 of the ZDDS).

The Revenue Authority shall verify the grounds for registration within 7 days from the submission of the application (Article 101, paragraph 6 of the VAT Act). This check may include checking documents, conducting counterchecks, and analyzing the person's activities. If the applicant submitted documents at the initial registration of the company with the Registry Agency, the NRA receives the information ex officio and carries out the verification in the same order.

After completion of the verification, the NRA has 7 days to issue an act of registration or a reasoned refusal (Art. 101, para. 7 of the VAT Code). In certain cases, registration takes place within a shorter period — 3 days from the submission of the application, when registration is mandatory due to intra-Community acquisitions, supplies with installation or other specific grounds (Art. 101, para. 8 of the GDPR).

If a person does not fulfill his obligation to register, the NRA has the right to register him ex officio by means of an act of registration (Art. 102, para. 1 of the GDPR). In this case, the date of registration is considered to be the date on which the obligation to register arose, and the person owes VAT retrospectively on all taxable supplies made after that moment. This means that the NRA can claim payment of VAT for the previous period, even if the company did not charge the tax on its invoices.

The date of VAT registration is considered to be the date of service of the registration act (Article 103 (1) of the ZVAT). With registration, the company receives a VAT identification number (BG number), which it must use in all commercial documents.

Upon registration, the person may request a VAT registration certificate, which is provided by the NRA in a protected format (Art. 104, para. 1 of the ZVAT). If the certificate is lost, destroyed or damaged, the company is obliged to notify the NRA within 7 days, after which a duplicate is issued (Art. 105 of the GDPR).

The registration procedure is the same for both compulsory and voluntary registration. The main difference is that with mandatory registration, the NRA may impose penalties if the person does not submit an application on time, while with voluntary registration, the company submits documents of its own accord. It is possible for the NRA to refuse registration if it finds that the firm has no real economic activity or there are risks of tax abuses.

Unlawful refusal of registration can be appealed in administrative and judicial order, and the company has the right to prove that it meets all legal conditions.

What are the documents required for VAT registration?

VAT registration in Bulgaria requires the provision of certain documents, which depend on the basis for registration. According to Art. 74 of the Regulations for the Application of the Value Added Tax Act (VAT), registration may be carried out by submitting an application for registration in a form to the competent territorial directorate of the National Revenue Agency or by applying for registration by choice to the Registry Agency, if the person chooses registration at the time of initial registration.

In cases where registration is carried out through the NRA, various documents must be attached to the application according to the basis for registration. When registering on the basis of Article 96, paragraph 1 of the VAT Act (compulsory registration due to the achievement of taxable turnover), a statement of the taxable turnover by month for the last 12 months shall be submitted, including all taxable supplies forming the turnover, in accordance with Article 74, paragraph 2, item 1 of the GDPR. If the turnover is reached within a shorter period (up to two consecutive months, including the current one), the report must also include the turnover for the current month until the date of reaching the threshold.

If the registration is carried out on the basis of Article 99, paragraph 1 of the VAT Act (compulsory registration in case of intra-Community acquisition), it is necessary to submit a statement on the total amount of taxable intra-Community acquisitions for the current calendar year, excluding acquisitions of new vehicles and excise goods (Article 74, paragraph 2, item 2, item). 2 of the VAT Act).

When registering a foreign person who wishes to register under Art. 133 of the ZVAT, additional documents are required. According to Art. 74, para. 3 of the GDPR, the person must submit a certificate of current tax registration from the competent tax authorities abroad, accompanied by an official translation. In addition, when registration requires the appointment of an accredited representative, a notarized contract between the foreign person and the representative is presented, as well as a copy of the identity document of the accredited representative, if he is an individual.

If the registration is requested at the initial registration of the company with the Registry Agency, it is not required to submit a statement of taxable turnover, but the person is obliged to declare an e-mail address for correspondence in the NRA within 3 days, if one is not registered in the Commercial Register (Art. 74, para. 5 of the GDPR).

Upon completion of the registration procedure, the registered person may request a VAT registration certificate, which is issued in the form according to Art. 75 of the PPZVAT. The certificate shall have an official protected format and additional copies may be issued if necessary.

If the certificate is lost, destroyed or damaged, the person is obliged to notify the NRA within 7 days, after which the tax authority issues a duplicate (Art. 105 of the ZVAT).

All documents submitted for registration must be complete and correct, since the NRA has the authority to conduct checks and refuse registration if there are doubts about the real economic activity of the company. Failure to provide the necessary documents may result in a refusal of registration, which is subject to appeal in administrative and judicial order.

What is the termination of registration (deregistration) under the VAT? When is it mandatory?

Termination of registration under the Value Added Tax Act (VAT), known as deregistration, is a procedure by which a person loses his or her status as a VAT-registered person. After the date of deregistration, the person is not entitled to charge VAT and cannot deduct a tax credit, except in cases where the law provides otherwise (Art. 106, para. 1 of the VAT Code). Deregistration can be carried out on the initiative of the person or the revenue authority, when there are legal grounds for this (Art. 106, para. 2 of the VAT Act).

The law distinguishes between compulsory deregistration, which is carried out when certain circumstances have occurred, and optional deregistration, which can be requested by the person when the grounds for registration are no longer available.

The grounds for compulsory deregistration are listed in Art. 107 of the ZVAT and include various cases of termination of the person's activity. Such are the death of a natural person, including a sole trader, as well as the deletion of the sole trader from the Commercial Register, unless the person chooses to continue his VAT registration. Upon termination of a legal entity without liquidation or upon termination with liquidation, if the company does not file a declaration on the continuation of registration, it is also subject to deregistration. In addition, if an unpersonified company or insurance fund is terminated, as well as if a branch of a foreign legal entity is deleted, deregistration is also carried out (Art. 107, item 6 and item 7 of the ZVAT).

In addition to compulsory deregistration, Art. 108 of the VAT Act provides for optional deregistration when the grounds for compulsory registration cease. This means that if a person has been registered under Art. 96, para. 1, Art. 97 or Art. 100, para. 1, but no longer reaches the required taxable turnover, he can file an application for deregistration. Likewise, a person who is registered for intra-Community acquisitions may deregister if, in the preceding calendar year, the amount of taxable intra-Community acquisitions does not exceed EUR 10 000.

The law provides for a minimum registration period before a person can deregister by choice. According to Art. 108, para. 2 of the ZVAT, a company that has registered by choice (Art. 100 of the ZVAT) may not submit an application for deregistration earlier than 12 months from the beginning of the calendar year following the year of registration. This means that if a company decides to register voluntarily, it must remain registered for at least one full calendar year.

The procedure for deregistration on the initiative of the person is described in Art. 109 of the ZVAT. In cases of termination of a legal entity or deletion of a sole trader, the application for deregistration must be submitted within 14 days from the occurrence of the relevant circumstance. In cases where the person chooses to deregister, he has the right only to determine the moment of filing the application.

After submitting the application, the revenue authority carries out an inspection within 7 days. If the grounds are present, the NRA issues an act of deregistration, by which it terminates the registration. The date of deregistration is considered to be the date of occurrence of the circumstance (for example, the date of liquidation of the company) or the date of service of the deed of deregistration (Art. 109, paras. 6 and 7 of the VAT Code).

Deregistration can be carried out on the initiative of the NRA if the revenue authority establishes that the person was obliged to submit an application for deregistration, but did not do so (Art. 110, para. 1, item 2 of the ZVAT). In these cases, the NRA has the right to terminate the registration ex officio, and the date of deregistration will be the date of occurrence of the grounds for it.

As of the date of deregistration, the person is deemed to be supplying all available goods and services for which he used a tax credit (Art. 111 (1) of the VAT Code). This means that upon termination of registration, the company must charge VAT on the assets it still owns and for which it has benefited from a tax credit in the past. The tax is included in the last VAT return that the person submits and must be paid to the budget.

The law provides for exceptions to the accrual of VAT upon deregistration. For example, if the company re-registers within the same tax period, it will not owe VAT on its assets (Art. 111, para. 2, item 5 of the VAT Act).

After deregistration, the person must keep his tax documentation for 5 years, being obliged to provide information to the NRA upon request. If a person who has been deregistered resumes his activity and again reaches a taxable turnover of more than 84 874 euros, he will be obliged to re-register under the VAT.

What are the necessary documents for VAT deregistration?

In order for deregistration under the VAT to be carried out, it is necessary to submit certain documents regulated in Art. 77 of the Regulations for the Implementation of the Value Added Tax Act (VAT). The main document to be submitted is an application for termination of VAT registration (Appendix No. 8), which is submitted to the competent territorial directorate of the NRA.

Additional documents are necessarily attached to the application, which vary depending on the grounds for deregistration. In case of termination of registration due to a decrease in taxable turnover below the threshold for compulsory registration or by choice, a reference is required for the taxable turnover by months for the last 12 months preceding the current month, and the turnover for the current month up to the date of submission of the application (Article 77, paragraph 2, item 1 of the VAT Act).

If the person is registered under Art. 99 of the VAT Act (in case of intra-community acquisition), a statement of the total amount of taxable intra-community acquisitions for the previous and current year must be submitted. In cases where the registration was on the basis of Article 99, paragraph 7 of the GDPR, a reference is required for intra-Community acquisitions for the last 12 months prior to the current month (Article 77, paragraph 2, item 2 of the GDPR).

If the person received a VAT registration certificate at the initial registration, he must return it to the NRA when submitting the application for deregistration (Article 77, paragraph 2, item 5 of the PPZVAT).

Together with the reference-declaration for the last tax period, the person must submit a protocol-inventory for the accrual of tax under Art. 111 of the ZVAT (Appendix No. 9). This document is essential, since according to Art. 111 of the ZVAT, at the date of deregistration it is considered that the person carries out the supply of all available goods and services for which he used a tax credit. The protocol must be included in the sales log for the last tax period and declared in the last reference-declaration (Art. 77, para. 4 and para. 5 of the PPZVAT).

If the person is a legal entity in liquidation, but wants to remain registered until its final deletion from the Commercial Register, instead of an application for deregistration, he submits a declaration in free text to the NRA expressing his desire to keep his registration until the liquidation is completed (Art. 77, para. 7 of the PPZVAT).

For taxable persons who carry out only supplies to which special arrangements apply, such as the regime in the Union, outside the Union or the regime for the distance sale of goods, deregistration shall be carried out in a special order. They must register in another Member State for the application of the special regime or in Bulgaria under Article 154 or 156 of the ZVAT, and then within 14 days submit an application for deregistration under Annex No. 8 in the Official Gazette of the NRA Sofia (Art. 77a, para. 1 of the PPZVAT).

After submitting the application for deregistration, the NRA carries out an inspection within 7 days (Art. 77a, para. 3 of the GDPR). If the grounds for deregistration exist, within another 7 days the revenue authority issues an act of deregistration (Art. 77a, para. 4 of the PPZVAT). The date of deregistration is considered to be the date of occurrence of the relevant circumstance (for example, the date of registration in another Member State) or the date of issue of the deed of deregistration (Article 77a (5) of the GDPR).

There are cases when a person does not have the right to terminate his registration. This applies to persons registered under Art. 132, para. 5 of the GDPR, if one of the partners is registered under VAT (Art. 77, para. 6 of the GDPR).

After the deregistration procedure is completed, a person must keep all documents related to his VAT registration for a period of 5 years, during which he can be subjected to tax checks and audits. If the grounds for registration subsequently arise, a person will be obliged to re-register, following the procedures described in Chapter Nine of the VAT Act.

What are the special cases of VAT registration and deregistration?

Especial cases of registration and deregistration under the VAT Act cover situations in which specific circumstances arise requiring registration or termination of registration outside the standard rules. Such cases include the transformation of companies, succession, registration of foreign persons, as well as certain specific regimes for electronic commerce and international trade.

A. This applies to cases such as a merger, merger, division, separation or transfer of an enterprise. A. The date of registration coincides with the date of registration of the conversion (Art. 132, para. 3 GDPR).

When registering an unincorporated company, if at least one of the partners is registered for VAT, then the company is also subject to mandatory registration. In such a case, the registration must be carried out within 7 days from the creation of the company or from the moment the partner acquires VAT registration (Art. 132 (5) and (6) of the VAT Act).

When registering an inheritance, if a sole trader or a natural person registered for VAT dies, but his enterprise is taken over by an heir or testator, the new owner has the right to continue the VAT registration (Art. 132a, para. 1 of the ZVAT). To do this, he must submit an application within 7 days of the acceptance of the inheritance, but no later than the 14th of the month following the 6th month from the date of death of the heir (Art. 132a, para. 2 of the VAT Code). The date of registration is considered to be the date of service of the registration act (Art. 132a, para. 3 of the GDPR).

A specific case is the registration of a foreign person who is not established in the country. A foreign person with a permanent establishment in Bulgaria who carries out taxable supplies is obliged to register under the VAT Act (Art. 133, para. 1 of the VAT Act). A registration is carried out through an accredited representative. Persons who are not established in the country, but carry out taxable supplies with a place of performance in Bulgaria, are also subject to registration through an accredited representative (Art. 133, para. 2 of the GDPR).

If a foreign person does not appoint a new accredited representative within 14 days of the termination of the previous one, the NRA may terminate his registration on the initiative of the Revenue Administration (Art. 133, para. 4 of the GDPR). In such cases, an act of deregistration is issued, and the date of termination coincides with the expiration of the term for a new representative (Art. 134, paras. 3 and 4 of the GDPR).

A special case of deregistration is the termination of the registration of a foreign person. If a foreign person registered for VAT in Bulgaria ceases to carry out taxable supplies, he or she may submit an application for deregistration under Article 109 of the VAT Act. In other cases, the NRA may terminate the registration ex officio (Art. 134 (1) and (2) of the GDPR).

An accredited representative of a foreign person may be a natural or legal person who is a resident for tax purposes, is not in liquidation proceedings and has no outstanding public obligations (Art. 135, para. 1 of the VAT Act). An accredited representative is jointly and severally liable for the tax obligations of the represented person (Art. 135, para. 3 of the GDPR).

Another specific case is the registration for the special modes in remote sales. A taxable person who sells goods or services to consumers in other Member States may register for a regime in the Union, a regime outside the Union or a regime for distance sales of goods imported from third countries (Articles 154 and 156 of the VAT Code). Registration in Bulgaria is optional if a person does not wish to register in another Member State.

In the case of deregistration of persons using special regimes, the procedure is carried out by submitting an application to the NRA Sofia within 14 days of registration in another Member State or upon termination of the activity (Art. 77a, para. 1 of the GDPR). In this case, the date of deregistration is considered to be the date of registration in the new state or the date of the application for termination of registration (Art. 77a, para. 5 of the GDPR).