Change in VAT registration turnover 

One of the most important elements of the VAT changes in Bulgaria for 2023 is the change in VAT registration turnover. As of 1 January 2023, taxable persons established in Bulgaria will be subject to a mandatory VAT registration when they reach a taxable turnover of BGN 100,000 for a period encompassing the current month and 12 consecutive months prior to the current month.

The VAT registration turnover doubles compared to the previous BGN 50,000 threshold. The significant increase in the turnover requiring a VAT registration is designed as a tax relief measure for small and medium-sized enterprises which now incur significant compliance costs and which are less competitive due to the additional VAT on their goods and services.

The VAT registration turnover is meant to be further increased as of 2025 after EU Directive 2020/285 is transposed in the Bulgarian VAT Act. The new measure will, however, not affect not-established taxable persons who are subject to a VAT registration before they make any supplies taxable in Bulgaria.

New permanently reduced VAT rates

At the end of 2022 the Bulgarian Parliament transformed some of the temporarily reduced and last year already extended VAT rates into a permanent measure. The amendments to the Value Added Tax Act were published in the Bulgarian State Gazette No. 102 on 23 December 2021 and came into force on 1 January 2023.

The permanent VAT rate reduction applies to the following supplies:

• Books: 9% reduced VAT rate applies to books on a physical medium or by electronic means or both, including textbooks, learning books and learning sets, children’s picture, drawing or colouring books and music printed or in manuscript form with the exception of publications wholly or predominantly devoted to advertising and publications wholly or predominantly consisting of video content or audible music.

• Newspapers and magazines: Newspapers and magazines were initially left outside the scope of the reduced VAT rate and were subject to the standard rate of 20%. However, as of 1 January 2023 the supply of newspapers and periodicals will be taxable at the rate of 9% on a permanent basis.

• Baby food and diapers: The baby foodstuffs falling within the scope of the permanent 9% reduced VAT rate include adapted milk formula, baby porridges and cereals, vegetable, fruit and/or meat purees in jars not exceeding 250g. Baby diapers are also subject to a reduced 9% VAT rate.

Extended reduced VAT rates

The extended period of application of the reduced 9% VAT rate on the supplies listed below started on of 1 January 2023 and shall be in force until 31 December 2023:

• Restaurant and catering services: Restaurant and catering services consist of the supply of prepared or unprepared food, including take-away and delivery of food. The reduced rate does not apply to services consisting of the supply of wine, beer and alcoholic spirits. Take-away food from supermarkets and the like are excluded from the reduced rate. 

• Supplies under the special travel-agent VAT scheme: The reduced VAT rate also applies to supplies falling within the scope of the special travel-agent VAT scheme, as well as to the excursions organised by tour operators and travel agents with occasional passenger transport by bus. However, the overall application of the reduced VAT rate to these services may be called into question by the European Commission in the framework of an infringement procedure, as they already fall within the scope of a special margin scheme. 

• Supply of services for the use of sports facilities: The use of various sports facilities is also taxable under the reduced 9% VAT rate.

The super-reduced VAT rate of 0% which was introduced in the middle of 2022 and was initially designed to apply until 1 July 2023 shall now be in force for further six months until 31 December 2023. The 0% VAT rate applies to the following:

• Bread: “Bread” shall be understood as the product which is produced from the baking of dough as a mixture of wheat flour or another cereal, alone or in combination, and water, with or without adding salt, which rises using bread yeast or leaven, and technological additives (if necessary). 

• Flour: “Flour” shall be understood as the product which is a result of grinding bread wheat and which may be used for making bread and bread products.

If you would like to know more about the VAT changes in Bulgaria for 2023 or other tax rules in the country, please visit the homepage of Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria.

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VAT rate on central heating and natural gas

The first group of the consumer energy products in Bulgaria which are affected by the new tax measures are central heating and natural gas. To both supplies, a reduced VAT rate of 9% applies from 9 July 2022 until 1 July 2023.

Excise on LPG, natural gas and electricity

Similarly, from 9 July 2022 excise tax has been abolished for the following consumer energy products in Bulgaria:

• LPG (Liquefied Petroleum Gas) and natural gas used as motor fuels,
• heat energy,
• energy products used for the combined production of heat energy and electricity,
• electricity under code CN 2716 produced from the following renewable sources: solar, wind, wave, tidal or geothermal power; hydroelectric power; biomass or biomass-based products; methane emitted from abandoned coal mines and fuel cells.

The excise exemption for the above-listed consumer energy products in Bulgaria is planned to apply until 30 June 2025 provided that the European Commission does not consider the measure incompatible with state aid rules.

Compensation to consumers for high motor fuel prices

In order to be compensated for the surge in motor fuel retail prices, consumers in Bulgaria are provided with a discount from the retail prices of certain motor fuels.

The compensation is valid for the following motor fuels:

• gasoline,
• gasoil,
• LPG,
• natural gas.

The compensation for these consumer energy products in Bulgaria is provided in the form of a fixed discount of EUR 0.13 per liter/kilogram and is granted by retailers at the petrol stations from the retail price of the fuels. There is no limit on the quantity that may be purchased or in the number of purchases eligible for a discount. However, the grant of the discount by retailers is voluntary.

Only natural persons owning or using passenger motor vehicles, motorcycles and mopeds are entitled to the discount in Bulgaria after they prove their eligibility by presenting the vehicle registration certificate at the petrol station.

Retailers must account for VAT on the full price of the sold fuel and they are refunded the amount of the granted compensations on a monthly basis, within ten days after the deadline for filing the VAT return for the respective monthly period.

The fuel compensation also applies from 9 July 2022.

Other tax measures 

Apart from the tax relief for consumer energy products in Bulgaria, other provisions have been introduced also in an effort to overcome the effects of increased consumer prices and inflation. Thus, zero VAT rate applies on the supply of bread and flour for one year, and the supply of beer, wine and alcoholic spirits shall be explicitly excluded from the scope of the 9% reduced VAT rate on restaurant and catering services and consequently should be taxable at the standard 20% rate.

If you would like to know more about the tax relief for consumer energy products in Bulgaria or other tax changes in the country, please visit the homepage of Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria.

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Tax changes in Bulgaria on private use expenses

After discussing various alternatives for changing or even abolishing the tax on expenses related to the private use of company assets by employees, often referred to as “weekend tax”, the Bulgarian Parliament has finally settled on reducing the tax pursuant to an amendment published in State Gazette No. 17 on 1 March 2022.

The reduced tax rate concerns only in-kind expenses related to the private use of owned or rented company assets by its employees, directors and shareholders who work in the company. The in-kind expenses subject to tax are the accounting expenses corresponding to the private use of mixed-use assets that are exploited both in the business activities of the employer and for the private use of the employees against no consideration. Such assets normally comprise company cars, immovable property mobile phones, laptops, etc.

The taxable base for the final tax on expenses remains unchanged and continues to refer to the portion of the expenses related to the mixed-use assets that can be allocated to the private use by the personnel. The method of calculating the taxable portion in proportion to e.g. the hours of personal use, the mileage for personal use, or as a fixed percentage also remains the same. The tax on expenses is levied as a final tax on an annual basis.

The new tax rate on private use expenses is 3% which is a significant reduction from the previous rate of 10%. It applies as of 1 January 2022.

Changes related to distribution of food vouchers

The amendments published on 1 March 2022 also concern the distribution of food vouchers to employees which was hampered by the shortage of vouchers after the tax-exempt maximum monthly value of vouchers was increased to BGN 80 (EUR 41) per employee. In order to ensure that employees will receive the entire amount of food vouchers that they are entitled to, the law has been changed so that in 2022 vouchers for previous periods may be distributed to the employees during any of the following months provided that the maximum non-taxable value for any given month is not exceeded.

Repeal of personal income tax on bank deposits interest

Recent tax changes in Bulgaria affect also the personal income tax (PIT), as the final PIT on bank deposits interest has been repealed pursuant to an amendment published in State Gazette No. 17 on 1 March 2022.

Bank deposits interest income received by natural persons was subject to a final tax on the gross interest income at the rate of 8%. The repeal of the interest tax was part of the tax policy plan of the new coalition government and by virtue of the latest statutory amendments the final tax was indeed abolished.

Following the repeal of the final tax, the income from deposits held in banks or bank branches established in Member States of the European Union (EU) and the European Economic Area (EEA) is included among the tax-exempt items of income under the Personal Income Tax Act. The term “deposit” should be interpreted within the meaning of the statutory definition of the Bank Deposits Protection Act. Judging from the wording of the tax exemption, it seems that interest from deposit accounts held in banks established outside the EU or EEA may be taxable under the general rules which in effect should lead to a 10% tax on non-exempt interest income.

The repeal of the final PIT on bank deposits interest applies as of 1 April 2022. 

Reduced VAT rate on specialised milk formula and baby food

As part of the latest tax changes in Bulgaria, the scope of the reduced VAT rate which currently applies to certain baby foodstuffs was further extended pursuant to an amendment to the VAT Act published in State Gazette No. 14 on 18 February 2022.

The reduced VAT rate of 9% shall apply to specialised milk formulas (with partially hydrolysed protein and those for children with allergies) and diet foods for special medical purposes intended for infants falling within CN codes 2106 90 92 and 2106 90 98 pursuant to the EU Combined Nomenclature.

The reduced 9% VAT rate on specialised baby food applies as of 18 February 2022 and shall be in force until 31 December 2022.

If you would like to know more about the latest tax changes in Bulgaria, please visit the homepage of Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria.

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The tax relief was originally introduced in July 2020 as a temporary measure to help the most affected businesses from the Covid pandemic situation recover and was initially meant to apply until 31 December 2021.

Extended period of application of the reduced VAT rate

The extended period of application of the reduced 9% VAT rate on the supplies listed below starts on 1 January 2022 and shall be in force until 31 December 2022.

Supplies subject to the reduced 9% VAT rate

The reduced 9% VAT rate shall continue to apply to the following supplies:

• Restaurants and catering services
  Restaurants and catering services consist of the supply of prepared or unprepared food, including take-away and delivery of food. The reduced rate does not apply to services consisting of the supply of alcoholic spirits. Takeaway food from supermarkets and the like are excluded from the reduced rate.

• Books
  The reduced VAT rate applies to books on a physical medium or by electronic means or both, including textbooks, learning books and learning sets, children’s picture, drawing or colouring books and music printed or in manuscript form.Outside the scope of the tax relief remain:
  – newspapers and periodicals;
  – publications wholly or predominantly devoted to advertising;
  – publications wholly or predominantly consisting of video content or audible music.

• Baby food and diapers
  The baby foodstuffs falling within the scope of the reduced VAT rate include adapted milk formula, baby porridges and cereals, vegetable, fruit and/or meat purees in jars not exceeding 250g. Baby diapers are also subject to the reduced 9% VAT rate.

• Supplies under the special travel-agent VAT scheme
  The reduced VAT rate also applies to supplies falling within the scope of the special travel-agent VAT scheme, as well as to the excursions organised by tour operators and travel agents with occasional passenger transport by bus.

• Supply of services for the use of sports facilities
  The use of various sports facilities is also taxable under the reduced 9% VAT rate.

If you would like to know more about the latest tax regulations in Bulgaria, please visit the homepage of Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria.

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Remote work, paid leave, unpaid leave

Employers whose activities have not been suspended during the emergency epidemic situation are entitled to introduce unilaterally home-office work or telework, without the consent of the employees or part-time work for all or part of the company. Additionally, the employers may grant up to one half of the paid annual leave to an employee without their consent.

If work has been suspended by order of the employer or by virtue of a state body act, the law provides several possibilities. The employer may unilaterally, without the consent of the employees, grant them their paid annual leave. The employer is not entitled to grant unpaid leave without the consent of the employee. However, the employer is obliged to grant the requested paid or unpaid leave to several categories of employees (incl. pregnant employees and employees at an advanced stage of IVF treatment, mothers or adoptive mothers of a child up to 12 years of age or of a disabled child, regardless of their age, etc.)

After 1 January 2021, the unpaid leave for a period of up to 60 days will be acknowledged in the labour legislation in Bulgaria as work experience. During 2021, up to 60 of those days will be acknowledged as social security periods.

Additional amendments in the area of labour legislation in Bulgaria

At the end of 2020, the National Assembly adopted several additional amendments in the area of labour legislation in Bulgaria which are aimed at primarily guaranteeing the rights and interests of employees and employers in this rapidly changing environment. The first relevant amendment concerns employees who have been in close contact with a confirmed case of COVID-19. The law provides that they shall switch to telework or the home office if the nature of the work allows this to be the case. Secondly, through collective bargaining, trade unions and employers at branch and sectoral level may negotiate a longer period of overtime, but not more than 300 hours in a calendar year. At the same time, the restriction set in the Labour Code for overtime work up to 150 hours per year, when no collective labour agreement has been concluded, is maintained.

Lastly, the legislator clearly regulated that the Bulgarian Labour Code is the applicable law for employment relationships with an international element between an employer and an employee whose place of work is in Bulgaria or abroad, unless otherwise agreed in the employment contract or provided for in the labour legislation in Bulgaria or in an international contract, which is in force for Bulgaria. The aim is to ensure equality for employees, as well as the opportunity to enjoy the protection of labour legislation, irrespective of their citizenship.

If you would like to know more about the labour legislation in Bulgaria, please visit the homepage of Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria.

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Deferred accrual of VAT or reverse-charge mechanism on import in Bulgaria

Pursuant to art. 211 of the EU VAT Directive, from 1 July 2019 Bulgaria will apply the so-called deferred accrual of VAT or reverse-charge mechanism on imports of certain goods. The newly introduced rules regarding the reverse-charge mechanism on import in Bulgaria will be applicable to certain categories of taxable persons and will cover the importation of the goods listed in Appendix No. 3 to the Bulgarian VAT Act. The list of goods includes ferrous and non-ferrous metals, ores, organic and non-organic chemical products.

The importers who are entitled to apply the reverse-charge mechanism on import in Bulgaria should meet all of the following conditions:

• they must have been registered for VAT purposes in Bulgaria under the general VAT registration rules at least six months prior to the import,
• they should not have any outstanding public liabilities, and
• the customs value of each item declared for import must be equal to or higher than BGN 50,000 (roughly EUR 25,500).

The right to input VAT deduction is applied through the monthly VAT return submitted by the importer by including the import customs declaration and the protocol for VAT reverse-charge in the monthly VAT sales and purchase ledgers. Thus, the importer is entitled to enjoy input VAT deduction without the import VAT being effectively paid to the customs office upon importation of the goods.

Triangular operations

Apart from the introduction of the reverse-charge mechanism on import in Bulgaria, the conditions which should be cumulatively fulfilled so that the triangulation simplification applies, has been changed. Following the latest amendment to the Implementing Regulation to the VAT Act, these conditions are as follows:

• The supply of goods must be carried out between three taxable persons;
• A VAT-registered person in member state A (transferor) supplies the goods to a VAT-registered person in member state B (intermediary). Subsequently, the intermediary from state B supplies the same goods to the end customer registered in member state C (acquirer);
• The goods should be transported directly from member state A to member state C;
• The intermediary should not be registered for VAT purposes in either state A or state C. Nevertheless, this condition shall be deemed fulfilled even in the event that the intermediary is VAT-registered in member state A or C, but has performed the intra-Community acquisition of the goods under its VAT ID number issued in member state B.
• The acquirer accounts for the VAT due in relation to the supply.

 VAT treatment of vouchers

The Vouchers Directive (EU) 2016/1065 of 27 June 2016 was implemented in Bulgarian VAT law as of 1 January 2019. The newly adopted provisions introduced the terms ‘single-purpose voucher’ and ‘multi-purpose voucher’ and establish the rules for their VAT treatment.

The new rules apply for vouchers issued after 31 December 2018.

Click here if you want to read the original article about the introduction of the reverse-charge mechanism on import in Bulgaria and other VAT-changes in the country on the website of Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria.

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The new requirements apply to sales management software understood as software or a module thereof, irrespective of the underlying technology, used to process information about the sales of goods and/or provision of services in sales outlets, where the issue of a cash receipt for the payment is required. In practice, this covers all sales outlets which accept payments in cash, with bank cards or vouchers.

Who do the new requirements apply to, and why? 

It is also clarified that “sales management” using sales management software constitutes the automated processing of information about the sales of goods or services, which comprises tracking the movement of goods or execution of services from their order until provided and/or paid for. Additionally, to determine whether software used by a company is sales management software subject to the new requirements, the Bulgarian National Revenue Agency (NRA) has prepared a self-assessment questionnaire.

The new requirements aim to combat tax fraud and tax evasion and ensure that a cash receipt is issued and information is transmitted to the NRA for every sale recorded in the software. Many companies currently use sales management software, but the software is either not connected to the cash registers, or allows the cash registers to be manipulated so sales are not recorded, duly documented and reported to the NRA.

Requirements for sales management software

Sales management software must be connected to the cash registers installed by the merchant and must control them. All sales management software must meet a number of requirements, including, for example:

• supporting an interface in Bulgarian;
• having built-in protection against change or the addition of external modules allowing a modification of the software’s functionality aimed at circumventing the requirements;
• built-in controls for the mandatory input of data for users and their unique authentication;
• ensuring that each sale processed through the software is closed with the issue of a cash receipt, etc.

The deadline for making sales management software compliant is 31 March 2019.

Requirements for sales management software producers/distributors

Persons established in the EU who produce and/or distribute sales management software in Bulgaria have the following obligations:

a) Filing a compliance declaration

A compliance declaration form must be submitted to the NRA with the following information:

• name and version of the sales management software;
• declaration that the software complies with the new requirements;
• declaration that the software does not comprise modules allowing the circumvention of the new rules;
• declaration that they do not produce or distribute software aimed at changing the software functions in a way that circumvents the new requirements, or which otherwise change, erase or manipulate the information in the software database.

If the sales management software is produced by a person established in an EU Member State other than Bulgaria, the compliance declaration is filed either by the producer or by an authorised distributor of the software for Bulgaria.

The declaration form is filed electronically through the e-portal of the NRA by 31 March 2019.

b) Providing information about the sales management software

Together with the compliance declaration, the producer/distributor of the sales management software must provide the following information about the software:

• information about the modules of the software and their functionalities; technological and system environment where the software operates; how the software is provided to clients (e.g. as a SaaS, web-based, local installation, etc.); type of database; encryption algorithm; authentication of users; etc.;
• manual for working with the sales management software;
• for software which is installed in the client’s environment – description of the objects in the database related to the sales management, relations between them, description of the cells in the tables as well as an exe. file and the source code generating the exe. file for accessing and extracting data from the database in a structured and readable format;
• for Software as a service (SaaS) – description of the service functionality; technical channels for communication between the cloud service and the cash registers; communication ports; description of the local components installed in the client’s environment; physical location of the database.

If any of the declared circumstances change, the producer/distributor must inform the NRA of the change within seven days.

The sales management software is then included on a public list of the software programmes which comply with the new legal requirements.

c) Obligation to cooperate with the NRA

The sales management software database must be stored in an EU Member State and, upon request, the producer/distributor must cooperate with the NRA by providing information on and/or access to the database.

Requirements for merchants using sales management software

Merchants using sales management software are required to:

• only use software which meets the legal requirements and is included on the public list of compliant software – in this regard, a declaration form on the sales management software used by the merchant must be filed by 31 May 2019;
• make sure that the sales management software manages all cash registers in their sales outlets;
• store the database of the software in Bulgaria or in another EU Member State;
• when the sales management software operation involves receiving or transmitting information from/to other software or modules – the information generated through such software or modules must be stored for the periods set for storing tax information (i.e. ten years) and access to it should be granted to the NRA with a right to read and export data;
• insert the names of each user (operator) of the sales management software according to the employment agreement with the users, their assigned role and the activation period for the assigned role.

In addition, certain new requirements are introduced for cash registers and the content of cash receipts. All producers of cash registers and the merchants using the cash registers must comply with these new requirements by 31 March 2019, which may require upgrading existing or buying new cash registers.

If you would like to know more about the new requirements for sales management software or other taxation issues in Bulgaria, please visit the homepage of Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria.

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In the Bulgarian State Gazette No. 80/28.09.2018 changes to Ordinance H-18 on the registration and reporting through fiscal devices of sales in commercial premises, the requirements for the software for their management and the requirements for the persons who make sales through on-line stores (Ordinance H-18) were promulgated. These changes introduce for the first time requirements for persons selling on-line in the tax legislation.

The purpose of the changes is for the National Revenue Agency of the Republic of Bulgaria (NRA) to have access to information about the persons who carry out sales through on-line stores, as well as to maintain a public list where anyone will be able to verify the owner of a specific on-line store.

The changes in Ordinance H-18 shall enter into force on 28. December 2018.

Whom do the new requirements apply to?

The requirements introduced with Ordinance H-18 apply to all persons who sell goods or services through an on-line store, irrespective of whether they use their own domain, leased domain or domain of another party, providing a platform for making sales on the Internet.

According to the legal definition in Bulgaria an on-line store is an Internet website through which sale of goods or services is carried out by concluding a distance contract under Article 45 of the Consumer Protection Act and which has a built-in functionality to select, include and exclude goods/services in a shopping basket, to submit information about the buyer, the delivery address and to choose a method of payment.

What are the obligations of the persons selling through an on-line store?

Persons who carry out sales through on-line stores are obliged to submit certain information to the NRA prior to conducting activity through their on-line store. The submission of the information shall be made electronically with a qualified electronic signature through an electronic service in the Eservice portal of the NRA. If a trader offers goods or services through several on-line stores, information shall be submitted separately for each on-line store.

Upon changes in the declared data or upon termination of the activity of the on-line store, up-to-date information shall be submitted to the NRA within seven days from the change or the termination of the sales through on-line stores.

In addition, the persons are obliged to store the information created through the software of the on-line store (current database and archive copies of the database) until expiry of the ten-year statute of limitations for payment of the respective tax liabilities under the Bulgarian Tax and Social Security Procedure Code.

What data are provided to the NRA?

The information that must be submitted to the NRA before the commencement of the sales through on-line stores includes:

• data about the on-line store – name, domain, data about the owner of the domain of the online store, where the on-line store’s website is hosted, who maintains the on-line store’s website, what software is used and where the software database is stored, starting and ending date of the operations of the on-line store;
• data about the person conducting sales through on-line stores – name, seat, registered address, address where the business activity is conducted, electronic address and telephone number, VAT registration status;
• data on the on-line sales – whether sales are made though an online platform or through an own store, what goods and services are sold.

All required information is provided in accordance with a template contained in Appendix No 33 to Ordinance H-18.

What is the deadline for submitting information by persons who already make sales through on-line stores?

If at the date of entry into force of the new requirements for on-line stores – 28. December 2018 the persons already carry out commercial activity through an on-line store, they should submit the required information to the NRA no later than 28. March 2019.

If you would like to know more about the new requirements for sales through on-line stores or other taxation issues in Bulgaria, please visit the homepage of  Delchev & Partners Law Firm, the exclusive representative of WTS Global in Bulgaria!

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