Art. 97a VAT Filing in Bulgaria

What is Art. 97a of the VAT Act?

Quick answer: Art. 97a of the Bulgarian VAT Act requires anyone providing B2B services to VAT-registered businesses in the EU to register for VAT in Bulgaria — even with zero domestic turnover. They charge 0% Bulgarian VAT but must file a monthly VAT return and VIES declaration by the 14th of the following month.

Art. 97a registration applies to individuals and companies providing services to VAT-registered businesses (B2B) in other EU member states. Typical examples:

• Online teachers and coaches — providing training to European companies or platforms
• Freelancers (design, development, copywriting) — serving EU clients
• IT consultants and SaaS providers — with corporate EU customers
• Translators, accountants, lawyers — delivering services across the EU

Monthly obligations

Those registered under Art. 97a must submit three documents each month by the 14th of the following month:

1. VAT Return (Справка-декларация)

The standard monthly VAT declaration. Under Art. 97a:

• Box 18 — taxable base for services to EU taxable persons (Art. 21(2) of ZDDS)
• Boxes 01–17 — typically zero (for EU-only service providers)
• Box 20 — output VAT = 0 (you do not charge Bulgarian VAT)
• Box 41 — VAT due = 0 (assuming no input VAT purchases)

The return is filed electronically through portal.nra.bg using a Qualified Electronic Signature (QES/KES).

2. VIES Declaration (Appendix 4)

For each EU client you invoiced, you report:

• Their VAT number (e.g. DE123456789)
• Their country
• The total taxable base (sum of all invoices for the month)

3. Sales ledger (Дневник продажби)

Every invoice issued during the month must appear in the sales ledger. Under Art. 97a, invoices carry 0% VAT but are still required entries.

Step-by-step: the monthly process

Here is what the monthly filing cycle looks like in practice:

Step 1: Issue the invoice

Issue an invoice to your EU client. It must include:

• Your EIK / VAT number (format: BG + EIK)
• The client's EU VAT number
• The text: "Reverse charge / Облагане в страната на получателя – чл. 21, ал. 2 ЗДДС"
• Amount excluding VAT (VAT = 0)

Step 2: Record the invoice in your accounting system

Enter the invoice as a sale at 0% VAT to an EU counterparty, including:

• The taxable base (amount)
• The client's VAT number
• The client's country

Firmify automatically detects EU counterparties (Country ≠ BG + VAT number present) and marks them as VIES entries.

Step 3: Close the monthly VAT period

At month-end, close the VAT period in Firmify. The system calculates:

• Total taxable base for Box 18
• VIES summary per VAT number and country
• Whether any VAT is due (relevant if you have input VAT with right of deduction)

Step 4: Download the XML

Generate the export XML from the NAP Export section in Firmify. The file includes:

• The VAT return with Box 18 populated
• VIES Appendix 4 (for EU clients)
• The sales ledger

Step 5: File on the NRA portal

Log in to portal.nra.bg with your QES and submit the documents. The NRA system accepts file uploads or allows manual entry of figures.

Deadlines and penalties

Penalties for late or incorrect filing:

• BGN 500–3 000 fine for unfiled or late declarations (Art. 180 ZDDS)
• Interest on any VAT due — base rate + 10%
• Intentional tax evasion — criminal liability

Deregistration from Art. 97a

You may apply to deregister when:

• You no longer have EU B2B clients
• You move to standard registration under Art. 96 (threshold reached)
• You cease the activity

Submit a deregistration application to NRA. Monthly returns must continue until deregistration takes effect.

DIY or accountant?

With just one invoice per month (typical for Art. 97a freelancers) self-service with Firmify is entirely realistic — the whole process takes under 30 minutes.