How are sales documented and reported through an online store?
The documentation and reporting of sales through an online store in Bulgaria is based on several requirements and procedures that must be followed.
First of all, when making sales through an online store, it is mandatory to issue a cash receipt or electronic invoice for each transaction. According to the Law on Value Added Tax (VAT), every sale must be documented with a fiscal cash receipt issued by a fiscal device (Art. 118, para. 1 of the VAT). The fiscal receipt must contain all the necessary requisites, including the name of the good or service, quantity, unit price, total value of the sale and VAT charged.
In cases of online sales, Ordinance No H-18 of December 13, 2006 requires merchants to use sales management software (PTO) that is related to the NRA and meets the requirements specified in Annex No. 29 (Art. 52a, para. 1 of Ordinance No N-18). The software must register each sale and generate the necessary documents, such as fiscal receipts and electronic invoices.
Do I need a cash register for my online store?
Whether it is necessary to use a cash register for an online store depends on several factors related to the methods of payment and the requirements of the Bulgarian legislation. The matter is mainly regulated by the Law on Value Added Tax (VAT) and Ordinance No H-18 of 13 December 2006.
For online stores that accept payments by bank transfer, credit and debit cards, direct debits or postal money transfers, it is not mandatory to issue a fiscal receipt. In these cases, the trader must provide the customer with a document containing minimum information such as the name of the trader, description of the goods or services, quantity and price (Art. 3, para. 1 of Ordinance No H-18).
In cases where payments are made by available cash, the merchant is obliged to use a cash register and issue a fiscal cash receipt. This requirement is mandatory for all merchants who accept cash payments (Art. 118, para. 1 of the VAT Code).
There are also alternatives to the traditional cash register when it comes to online trading. For example, if the online store uses Sales Management Software (PTO) that is affiliated with the National Revenue Agency (NRA) and meets the requirements of Ordinance No H-18, an electronic cash register or electronic invoices can be used. These electronic documents can replace traditional paper receipts, as long as the software generates and stores all the necessary sales and payment data (Art. 52a, para. 17 of Ordinance No H-18).
By using the standardized audit file (SAF-T), which replaces paper fiscal notes, it is also possible to avoid the need for a physical cash register. In this case, all transactions must be registered and stored electronically, with the data periodically sent to the NRA (Art. 52a^1, para. 5 of Ordinance No H-18).
What is the “Standardized Audit File”?
The standardized audit file (similar to SAF-T- Standard Audit File-Tax, v.2.0) is a standardized electronic format for the exchange of accounting information between traders and tax authorities. The SAF-T file can replace the paper fiscal note as long as electronic cash receipts are issued (Art. 52a, para. 17 of Ordinance No H-18). This file contains detailed information about all sales, including data on goods or services, customers, payments and accrued VAT.
The use of a SAF-T file facilitates tax checks and audits by providing access to detailed accounting information in a standardized format. In order to ensure compliance with the requirements of the NRA, traders must maintain up-to-date and accurate information on all financial transactions and submit the standardized audit file to the NRA annually by January 31 for the previous year (Article 52a^1, para. 5 of Ordinance No H-18).
In addition to issuing receipts and invoices, merchants must maintain a sales journal in which to record all sales made during the reporting period (Art. 123 and Art. 124 of the ZVAT). This journal must contain the document number, date of its issue, description of the goods or services, quantity, unit price, total value of the sale and VAT charged.
For sales within the European Union (EU), traders must comply with the VAT registration thresholds in the respective Member States. Until December 31, 2024, the threshold for mandatory VAT registration is BGN 100,000, and from January 1, 2025 this threshold will be increased to BGN 166 000 (Art. 96, para. 1 of the VAT Act). In addition, when purchasing services from third parties, for example, advertising, traders must apply the rules for VAT recalculation by issuing protocols under Art. 117 of the VAT Code for these services.
All documents related to sales and income reporting must be kept for a period of five years in accordance with Art. 38 of the Tax and Insurance Procedure Code (DOPC). Compliance with these requirements provides protection from potential sanctions and inspections, and non-compliance may result in fines and other administrative measures pursuant to Art. 185 and Art. 186 of the GDPR.
How are online cash on delivery sales accounted for in Bulgaria?
In the case of online cash on delivery sales, it is important to know exactly how to document and report these transactions in order to comply with the requirements of the Bulgarian legislation.
First, you must have the quality of a trader within the meaning of the Commercial Law in order to be able to carry out and report sales legally. Each merchant is obliged to register and report its sales, including those made through online stores, using appropriate documents and devices.
When using cash on delivery, the courier collects payment from the customer upon delivery of the goods. This amount is subsequently transferred to you, the trader, usually by bank transfer. It is important to know that when you have a contract with a courier company that is a licensed postal operator (for example, Econt Express Ltd or Speedy AD), the cash receipt can be replaced by a postal money transfer receipt. This receipt is a legally recognized document and has the same weight as the cash receipt (Art. 3, para. 1 of Ordinance H-18).
Thus, in cash on delivery sales, for which the courier issues a postal money transfer receipt, you do not need to issue an additional fiscal receipt. The receipt serves as proof of payment and must be attached to the invoice, if one is issued. This exempts the trader from the obligation to use a cash register for these transactions, as long as the conditions of Article 3, paragraph 1 of Ordinance H-18 are met.
The postal money transfer receipt is provided to the customer upon receipt of the goods and payment of the amount in cash. You, as a merchant, must keep a copy of this receipt and use it for accounting purposes. Thus, the accounting of the obligation as paid in cash is carried out on the basis of this receipt.
The amounts collected by the courier are transferred to the merchant's bank account, which also facilitates the reporting and storage of income data. It is important to make sure that the courier company you are working with is a licensed postal operator within the meaning of the Postal Services Act in order to take advantage of this opportunity. =