How to invoice foreign and EU clients from Bulgaria

How you invoice a foreign client from Bulgaria depends on three questions: is the client a business or a private individual, is it established in the European Union (EU), and are you selling a service or goods. A service to a business is taxed in the client's country, so the invoice carries no Bulgarian VAT and states "обратно начисляване" (reverse charge) with the legal basis under the Bulgarian VAT Act (ЗДДС). Goods for an EU business are an intra-EU supply at the zero rate, exports outside the EU are zero-rated too, and sales to private individuals carry Bulgarian VAT as a rule, with exceptions for electronic services and the OSS (One Stop Shop).

What goes on the invoice: a table by client

The table covers the most common cases for a supplier established in Bulgaria and registered for VAT there. A business that is not VAT-registered may not show VAT on its invoices (Art. 113, para. 9 of the VAT Act); what changes for it is covered below. Services under Art. 21, para. 4, for example those connected with real estate, follow their own rules and are not in the table. "The regulation" in the table is the regulation implementing the VAT Act (ППЗДДС).

An invoice to a private individual is, as a rule, not mandatory: it is issued if the client or the supplier wants one (Art. 113, para. 3, item 1 and para. 6 of the VAT Act). The exception is distance sales of goods supplied in Bulgaria when you are not registered for the Union scheme (Art. 113, para. 15). VAT-registered sellers record sales made without an invoice in a monthly sales report (Art. 119), as described in Stripe and the Bulgarian invoice.

Where is the place of supply of a service

The place of supply decides whether the invoice carries Bulgarian VAT: no tax under the VAT Act is charged on a supply whose place of supply is outside Bulgaria (Art. 86, para. 3). Services follow two main rules and several exceptions:

• 01The client is a taxable person, for example a company or a freelancer: the place of supply is where the client is established (Art. 21, para. 2 of the VAT Act).
• 02The client is a non-taxable person, for example a private individual: the place of supply is where you are established, that is Bulgaria (Art. 21, para. 1).
• 03Services connected with real estate, passenger transport and restaurant services have their own place of supply, whoever the client is (Art. 21, para. 4). Events and the other cases in the same paragraph also follow special rules.
• 04Consulting, accounting, legal and advertising services, software development and the other services in Art. 21, para. 5 are taxed where the private individual is, if that individual is established outside the EU.
• 05Telecommunications, radio and television broadcasting and electronic services to private individuals are taxed where the client is (Art. 21, para. 6), with a €10,000 threshold for clients in the EU (Art. 20b).

You may treat an EU client as a business when it has given you its VAT number and you have confirmed that the number, and the name and address linked to it, are valid (Art. 18(1)(a) of Council Implementing Regulation (EU) No 282/2011). The regulation applies directly. The check is made in VIES, the European Commission's VAT number system. For a client outside the EU, the evidence is a certificate from its tax authority, or a tax number combined with a reasonable check by normal commercial means (Art. 18(3)).

An electronic service is one delivered over the internet or an electronic network, essentially automated and with minimal human intervention (§ 1, item 14 of the supplementary provisions of the VAT Act and Art. 7(1) of Regulation No 282/2011). Examples include supplying software and its updates and website hosting. Advice that professionals such as lawyers and financial consultants give by email is expressly not an electronic service (Art. 7(3)(i)). When you are unsure how your service is classified, check with your accountant.

Services to an EU business: reverse charge and the VIES return

An invoice for services to an EU business carries no VAT: the client owes the tax in its own country, and you write "обратно начисляване" (reverse charge) and the legal basis instead of a rate and a VAT amount (Art. 114, para. 4 of the VAT Act and Art. 79, para. 2, item 3 of the regulation implementing it, ППЗДДС). The steps:

1. Check the client's VAT number in VIES and keep the result. The number goes on the invoice with its country code, for example DE123456789 (Art. 114, para. 1, item 8 of the VAT Act).
2. Issue the invoice within 5 days of the tax event, that is the day the service is performed, or of receiving an advance (Art. 113, para. 4 and Art. 25, para. 2). The deadline of the 15th of the following month applies to goods only.
3. Leave out the rate and the VAT amount. Write "обратно начисляване" and "чл. 21, ал. 2 от ЗДДС" (Art. 21, para. 2 of the VAT Act).
4. Enter the invoice in the sales ledger for the month in which it is issued (Art. 124, para. 2). In the VAT return, the taxable amount goes in cell 17.
5. File a VIES return (VIES декларация, the EU sales listing) for the same month together with the VAT return, by the 14th of the following month (Art. 125, paras. 2 and 5). Advance payments received for such services are included (Art. 117, para. 2, item 4, letter b of the regulation).

Charging no VAT does not cost you the input tax credit on related costs: Art. 69, para. 2, item 1 of the VAT Act keeps it for supplies made in another country that would carry the right to credit if made in Bulgaria.

Example: a web developer invoices a German GmbH €4,000.00

Pixel Code EOOD (a Bulgarian single-member limited company) in Sofia is VAT-registered and builds a website for Nordwerk GmbH in Berlin. The project is accepted on 30 September 2026 and the invoice is issued the same day. The names and numbers are made up.

Nordwerk GmbH accounts for German VAT itself, under the rules of its own country. Had the invoice been issued on 2 October, it would still be within the 5 days, but it would go into the sales ledger and the VIES return for October (Art. 124, para. 2 of the VAT Act and Art. 117, para. 4 of the regulation). The VIES return then also states September as the period in which the tax became chargeable (Art. 117, para. 2, item 11 of the regulation).

Goods for an EU business: the intra-EU supply

Selling goods sent from Bulgaria to a business in another member state is an intra-EU supply at the zero rate when the conditions of Art. 7, para. 1 and Art. 53 of the VAT Act are met:

• 01The goods are transported from Bulgaria to another member state by you, by the client, or on behalf of either.
• 02You are VAT-registered in Bulgaria.
• 03The client is registered for VAT in another member state and has given you its VAT number, which goes on the invoice (Art. 45, item 1, letter a of the regulation).
• 04You hold a transport document showing that the goods were received in the other member state. When the client transports them or has them transported, the client's written confirmation that it received them may be used instead (Art. 45, item 2 of the regulation). If you do not have the documents by the end of the month after the month the tax became chargeable, the zero rate does not apply (Art. 53, para. 3 of the VAT Act).
• 05You report the supply in a VIES return. Without it, or with inaccurate data, the supply is not an intra-EU supply unless you can justify the omission or error (Art. 7, para. 5, item 11).

The invoice states "обратно начисляване" (reverse charge) and the legal basis, for example "чл. 53, ал. 1 от ЗДДС" (Art. 79, para. 2, item 5 of the regulation), and is issued by the 15th of the month after the tax event, including for an advance (Art. 113, para. 5 of the VAT Act). The tax becomes chargeable on the 15th of the following month, or on the invoice date if the invoice is issued earlier (Art. 51, paras. 3 and 4), and the invoice goes into the sales ledger for that month (Art. 124, para. 3). In the VAT return, the taxable amount goes in cell 15.

Example: goods with a tax event on 20 October 2026 are invoiced on 3 November 2026. The tax becomes chargeable on 3 November, so the supply goes into the ledger and the VIES return for November, both filed by 14 December 2026. An advance received for an intra-EU supply does not make the tax chargeable (Art. 25, para. 7) and is not included in the VIES return (Art. 117, para. 4 of the regulation).

Clients outside the EU: exports of goods and services

Exporting goods outside the EU is a taxable supply at the zero rate (Art. 28 of the VAT Act): under item 1 when the goods are sent by you or on your behalf, and under item 2 when they are sent by or on behalf of a client not established in Bulgaria. The invoice states the zero rate and the basis, for example "чл. 28, т. 1 от ЗДДС" (Art. 114, para. 1, item 12). To prove the export you need a customs document naming you as the exporter and certifying that the goods left the EU, the invoice, and a transport document (Art. 21, para. 1 of the regulation). In the VAT return, the taxable amount goes in cell 14, and no VIES return is filed.

A service to a business outside the EU is also supplied where the client is established (Art. 21, para. 2 of the VAT Act). The regulation makes no distinction between clients in and outside the EU: the invoice states "обратно начисляване" (reverse charge) and "чл. 21, ал. 2 от ЗДДС" (Art. 79, para. 2, item 3 of the regulation). No VIES return is filed, because Art. 125, para. 2 covers only services with their place of supply in another member state. In the VAT return, the taxable amount goes in cell 18, for supplies in another country under Art. 69, para. 2.

Private clients: Bulgarian VAT or OSS

A sale to a private individual carries Bulgarian VAT as a rule, because the place of supply of the service is where you are established (Art. 21, para. 1 of the VAT Act). The main exceptions are the cases in Art. 21, para. 4, the services in Art. 21, para. 5 for individuals outside the EU, and telecommunications, broadcasting and electronic services (Art. 21, para. 6), described above.

For consumers in other member states, telecommunications, broadcasting and electronic services and distance sales of goods are taxed in Bulgaria as long as their combined value excluding VAT across all member states does not exceed €10,000 in the current calendar year and did not exceed it in the previous one (Art. 20b, paras. 1 and 2 of the VAT Act). The supply that crosses the threshold is already taxed in the consumer's country (Art. 20b, para. 3), at that country's rate (Art. 158, para. 6). You may also opt for taxation in the consumer's country below the threshold; the choice applies until the end of the second calendar year after the year you make it (Art. 20b, para. 4).

Above the threshold there are two routes: VAT registration in each client's country, or the Union scheme (OSS) with registration in Bulgaria (Art. 152, paras. 3 and 4 and Art. 156). Under the OSS:

• 01The scheme's VAT return covers each calendar quarter and is filed by the end of the month after the quarter (Art. 159, paras. 1 and 4 of the VAT Act).
• 02Invoicing follows the law of the member state of identification, that is Bulgarian law when you are registered here (Art. 158, para. 7).
• 03A person registered under Art. 96 or Art. 100, para. 1 draws up a separate sales report for supplies under the scheme, even when it has invoiced them (Art. 119, para. 5).
• 04A person established in Bulgaria may be registered under Art. 156 only. It then has no right to input tax credit (Art. 70, para. 4) and shows no VAT on invoices for supplies in Bulgaria (Art. 113, para. 9).

The €10,000 threshold and the OSS do not cover every service. A consultation for a private individual in Germany stays supplied in Bulgaria and carries Bulgarian VAT, whatever your turnover (Art. 21, para. 1).

Not VAT-registered: what changes

A company or freelancer without VAT registration that supplies services to EU businesses must register under Art. 97a, para. 2 of the VAT Act. The provision has no turnover threshold.

• 01The application is filed no later than 7 days before the date the tax on the supply becomes chargeable: the date of the tax event or of the advance (Art. 97a, para. 4).
• 02After registration, invoices to EU businesses look like the example, with "обратно начисляване" (reverse charge). A VAT return is filed for every month, and a VIES return for every month with such supplies (Art. 125, paras. 1, 2 and 4).
• 03A person registered under Art. 97a may not show VAT on its invoices (Art. 113, para. 9) and has no right to input tax credit (Art. 70, para. 4).
• 04Registration under para. 2 also counts as registration under para. 1 (Art. 97a, para. 3). Taxable services from foreign suppliers, for example Google ads, are therefore self-charged with an Art. 117 protocol.
• 05Para. 2 does not apply if you are registered in Bulgaria for the EU small business scheme in the client's member state (Art. 97a, para. 6).

How the protocol for services received is drawn up is covered in the Art. 117 protocol.

Services to businesses outside the EU do not trigger registration under Art. 97a, para. 2, which covers only services with their place of supply in another member state. Nor do they count towards the annual turnover compared with the €51,130 threshold for mandatory registration (Art. 96, para. 1), because that turnover includes only supplies with their place of supply in Bulgaria (Art. 168v, para. 1). Only a VAT-registered person can make an intra-EU supply of goods (Art. 7, para. 1).

Which currency and language the invoice must be in

Amounts on the invoice may be in any currency, but the taxable amount and the VAT amount are stated in euro (Art. 114, para. 5 of the VAT Act). The euro value uses the latest rate published by the European Central Bank (ECB) at the moment the tax becomes chargeable (Art. 26, para. 6). Example with an assumed rate of €1 = 1.1000 USD, for illustration only: an invoice for USD 5,500.00 also states a taxable amount of €5,000.00. For bookkeeping, the Accountancy Act (ЗСч) sets the euro value at the reference rate published by the Bulgarian National Bank on the date of the transaction (Art. 5, para. 1 of ЗСч). Setting the client's and the document's currency is covered in the guide Currencies and exchange rates.

The VAT Act does not regulate the language of an invoice; the rule comes from the Accountancy Act. Accounting documents are drawn up in Bulgarian, and for deals agreed in a foreign currency with foreign counterparties they may also be drawn up in the relevant foreign language and currency (Art. 5, para. 1 of ЗСч). An invoice in euro to a German company does not clearly fall under that exception, so a bilingual invoice in Bulgarian and English is the safer choice. An invoice to a foreign client also carries every item required by Art. 114 of the VAT Act, listed in Bulgarian invoice requirements.

Common mistakes

• 01"0% VAT" on an invoice for services to an EU business. Under the reverse charge the rate and VAT amount are left out, and "обратно начисляване" and the legal basis are written instead (Art. 114, para. 4 of the VAT Act).
• 02"No VAT" without a legal basis (Art. 114, para. 1, item 12).
• 03A client VAT number that was not checked in VIES or is written without its country code.
• 04No VIES return for services. It is filed for every month with such supplies (Art. 125, para. 2), and for goods, without it the supply is not an intra-EU supply (Art. 7, para. 5, item 11).
• 05A freelancer without VAT registration invoices an EU business without having applied under Art. 97a, para. 2 at least 7 days before the tax event or the advance.
• 06Charging the consumer's country VAT on every service to an EU individual. The €10,000 threshold applies only to telecommunications, broadcasting and electronic services and to distance sales of goods, and a consultation for a private individual carries Bulgarian VAT as a rule (Art. 21, para. 1).
• 07An invoice in English only for a deal in euro (Art. 5, para. 1 of ЗСч), or with a foreign-style number such as INV-2026-15 instead of ten digits (Art. 114, para. 1, item 2 of the VAT Act).
• 08A taxable amount in US dollars only, without the amount in euro (Art. 114, para. 5).

In smetni.app

In smetni.app the client record has a separate VAT number field, and you can check it in VIES and review the result. Each client has a preferred document language and currency that are used for new documents, and a document can be in a foreign currency. Invoice lines in the Sales module take a tax code, including "Reverse charge" and "OSS (distance sales)". If you work alone for clients abroad, see also smetni.app for freelancers. See the guides Clients and client portal and VAT and tax rates.