Al Hathaway Practical Guide · Bulgaria 2026
Article 97a VAT Registration in Bulgaria: A Practical Guide for Freelancers
Prepare before the first cross-border service. Understand the registration trigger, gather the right documents and build a monthly process for invoices, reverse-charge protocols and VIES.
Article 97a is a limited Bulgarian VAT registration for specified cross-border services. It can apply before a freelancer has substantial revenue. Check both the services you sell and the services you buy: registration, invoicing and reporting depend on the transaction, not simply on the customer’s country or the platform’s name.
Check both directions
When does Article 97a apply?
You receive a service
The service is taxable with a place of supply in Bulgaria and VAT is payable by you under Article 82(2). A foreign business tool, advertising or marketplace service may need this analysis.
You supply an EU service
You are established in Bulgaria and supply a qualifying Article 21(2) service in another EU member state, with VAT payable by the customer. Check the current small-enterprise-scheme exception.
Neither test is a substitute for identifying the service and the parties. A private customer, property-related service, exempt financial service or supply to a non-EU business may follow a different route.
Existing full VAT registration changes the starting point
If you are already fully registered, review the transaction under that registration rather than applying for another VAT number. If your position is unclear, use the registration act- not merely the VAT number- to identify the legal basis.
For the broader comparison with general and voluntary registration, see VAT Registration for Freelancers in Bulgaria.
Before tax becomes chargeable
When should the application be submitted?
The NRA states that the application must be submitted no later than seven days before the relevant VAT becomes chargeable, including through an advance payment or tax event. Treat this as an advance planning requirement, not seven days after receiving an invoice.
Planning example: a first EU assignment
You agree a project with a German business and expect a deposit before work begins. Send the contract and deposit date for review immediately. Do not schedule registration around the final invoice while ignoring the earlier payment.
Likewise, an automatically renewing subscription can create a transaction before you manually download the supplier invoice. Record the billing period and payment terms before activating the account.
Prepare a coherent file
What documents should you prepare?
The application identifies the registration basis and the date it arises. Supporting evidence should explain the actual transaction. The exact attachments and any further requests depend on your case; the list below is a preparation checklist, not a claim that every item is mandatory.
- Your registration details. Name, address, BULSTAT or company identification and current tax registrations.
- The underlying contract. Customer engagement, subscription terms or supplier agreement identifying the parties and service.
- The transaction timeline. Expected performance, billing periods, deposits and other advance payments.
- Counterparty evidence. Legal name, country, VAT number where relevant and the establishment receiving or supplying the service.
- The filing arrangement. Decide who submits the application, monitors NRA correspondence and handles the first VAT period.
The NRA’s guidance describes a three-day registration procedure for Article 97a. Allow time for accurate preparation and correspondence; an application receipt alone is not the registration act.
Outgoing EU services
How should an invoice to an EU business be prepared?
Before issuing the invoice, verify the contracting customer and the VAT treatment. Save evidence of the VAT-number check; do not copy a number from an email without validating it.
| Checkpoint | What to confirm |
|---|---|
| Parties | Correct legal names, addresses and relevant identification/VAT numbers. |
| Service | A meaningful description, price and performance or advance-payment date. |
| VAT explanation | The correct non-charging/reverse-charge wording for that supply, not a generic “0% VAT” label. |
| Reporting | The relevant VAT period and whether the supply or advance belongs in VIES. |
Limited registration does not authorise Bulgarian VAT on your sales
Article 113(9) prohibits persons registered only under Article 97a from showing VAT in their issued invoices. The correct explanation still depends on the supply. A VAT number and a zero-rated supply are not the same thing.
The NRA publishes invoice requirements applicable to independent economic activity, including free professionals. Have the first invoice template reviewed, then use it consistently with transaction-specific changes.
Received foreign services
What is a reverse-charge protocol?
Where you are responsible for Bulgarian VAT on a received service, the foreign supplier’s invoice and your Bulgarian tax-accounting document serve different purposes. An Article 117 protocol records your self-assessment; it does not replace the supplier’s invoice.
- Classify the supplier service. Confirm the contracting entity, place of supply, taxable status and recipient liability.
- Determine the chargeable date and base. Review advances, recurring service periods and any currency conversion.
- Prepare the protocol. Apply the statutory timing and required details to the actual transaction; keep it linked to the supplier document.
- Report and pay. Reflect the self-assessed tax in the correct registers and VAT return and settle the amount due.
A late supplier invoice, a fee deducted from your payout or an automated card payment is a reason to improve document collection- not to treat the received service as absent.
The recurring process
What must be filed each month?
The normal VAT period is the calendar month. The NRA requires the VAT return and purchase/sales registers by the 14th of the following month, electronically with a qualified electronic signature. The first period runs from registration to the end of that month.
| Item | Monthly action | Control |
|---|---|---|
| Supplier documents | Collect invoices, subscriptions and platform fee records. | Compare against bank/card payments and payout statements. |
| VAT return and registers | Prepare and submit the applicable monthly data. | Check acceptance, not just submission. |
| VIES | Report qualifying EU supplies where required. | Validate customer numbers and reconcile reportable amounts. |
| Payment | Settle VAT due within the applicable deadline. | Keep the payment reference and reconciliation. |
No transactions does not mean no VAT return
The NRA requires a return even where no VAT is payable and no supplies, acquisitions or imports occurred. VIES is different: it is required for reportable transactions, not automatically because you hold a VAT number.
VIES reports qualifying intra-EU activity. It is not a list of US clients, all platform income or foreign purchases. Its usual filing deadline is also the 14th of the following month.
Budget the real cost
Can you deduct the VAT self-assessed on a foreign service?
Not under Article 97a registration alone. The NRA explicitly excludes input-tax deduction for this limited registration. If a received service carries reverse-charge VAT, budget that VAT as a potential real cost.
Illustrative purchase
Assume a taxable foreign business service has a €250 base and Bulgarian VAT is self-assessed at 20%. The resulting tax is €50. If the recipient has only Article 97a registration, it cannot simply offset that tax through a matching input-VAT deduction.
Full registration can produce a different result, subject to the conditions for deduction. Compare the effect on customer pricing, eligible purchases and administration before choosing a voluntary registration route.
Review the contract, not the logo
How do Stripe, Upwork and foreign software fit?
Build an inventory of every supplier and product you use. Separate payment processing, marketplace access, advertising, billing tools and software subscriptions. A single platform statement can contain more than one type of charge.
Stripe and payment services
Check the specific fee and contracting entity. The payment-services exemption is not automatically available for every technical or administrative service connected with payments.
Marketplace payouts
Keep client revenue, commissions, refunds and payout transfers separate. A net deposit is not enough to identify the service purchased from the platform.
Before adding a new paid tool, send the supplier agreement and a sample invoice for review. This gives your accountant a chance to identify an obligation before the first automatic charge.
Keep the status under review
What if you need full registration or stop the activity?
Article 97a does not freeze your VAT position. Monitor other registration grounds as the activity changes. A new customer type, product or operating structure may require a fresh assessment.
The NRA provides a deregistration route for an Article 97a-registered person where no mandatory registration ground exists at the application date. Stopping one client contract does not prove that all grounds have ended: recurring foreign subscriptions may still be relevant.
Do not stop filing informally
Have the remaining obligations reviewed and retain the deregistration act. Plan the final VAT period rather than treating the last commercial invoice as the end of registration.
Frequently asked questions
Article 97a in practice
Can Article 97a apply to a free professional?
Yes. Independent economic activity can create VAT obligations for an individual as well as a company. Incorporation is not the deciding factor.
Should I wait until I have meaningful turnover?
No. Review the transaction before it occurs. Article 97a is a separate test from the general turnover threshold.
Is an EU customer’s advance payment relevant?
Yes. The NRA’s application timing expressly refers to advance payments as well as tax events. Do not review only the final invoice date.
Does a US customer alone create the EU-service trigger?
No. The outgoing-service limb concerns the relevant supplies in another EU member state. Received foreign services and other rules still need their own assessment.
Do I issue the reverse-charge protocol to my client?
A received-service self-assessment protocol is your tax-accounting document. It is different from the invoice you issue for your own services.
Must I file VIES when I only buy foreign software?
Purchases alone do not become reportable outgoing EU supplies. Check the transactions covered by VIES separately from the monthly VAT return.
What if I missed the registration date?
Preserve the original contracts, invoices and payment dates. Obtain a review of the correct registration basis, tax and reporting periods. Do not backdate documents.
Official sources and related guides
Complete Freelancing in Bulgaria guide · Freelancer tax and social security · Freelancer vs company
Set up Article 97a compliance around your actual transactions
Send Al Hathaway your customer contract, first payment date and foreign supplier invoices. We can help identify the registration basis and organise a clear monthly filing process.
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