Proforma invoice in Bulgaria: proforma vs invoice

A proforma invoice (проформа фактура) is a commercial document that states the price and terms and asks for payment before an invoice is issued. It is not a tax document: the Bulgarian VAT Act (ЗДДС) knows only the invoice, the note to an invoice and the protocol (Art. 112, para. 1). A proforma is not entered in the VAT ledgers, does not make VAT chargeable and gives no input tax credit. Once the client pays against it before delivery, the payment is an advance and the invoice is issued within 5 days of receipt (Art. 113, para. 4).

What a proforma invoice is

A proforma invoice is a request for payment laid out like an invoice, but without its legal effects. The VAT Act, the regulation implementing it (ППЗДДС) and the Accountancy Act (ЗСч) do not define it. The regulation mentions it only in Art. 110, para. 4: alongside an order form and a quote, a proforma is one of the supply documents attached to a VAT exemption certificate for bodies like diplomatic missions and international organisations.

As a result, a proforma:

• 01Is not entered in the sales or purchase ledger, which records tax documents (Art. 124, paras. 2 and 4 of the VAT Act).
• 02Does not make VAT chargeable: the tax becomes chargeable on the tax event date (данъчно събитие) or on receipt of an advance (Art. 25, paras. 6 and 7), proforma or not.
• 03Gives the buyer no input tax credit, which requires a tax document under Arts. 114 and 115 (Art. 71, item 1).
• 04Records no business transaction but proposes one. A primary accounting document carries information on a business transaction recorded for the first time (Art. 4, para. 2 of the Accountancy Act), so in practice a proforma is not treated as a primary document and is not booked.

Proforma vs invoice: the difference

The difference between a proforma and an invoice is legal status: an invoice is a tax document with a deadline, a number from the shared sequence and a place in the ledgers; a proforma has none of them.

When a proforma is not enough: payment before delivery

A proforma payment received before the tax event is an advance, and the proforma is no longer enough. VAT becomes chargeable on receipt, on the amount received, and is deemed included in it (Art. 25, para. 7 of the VAT Act). The supplier issues an invoice within 5 days of receiving the payment (Art. 113, para. 4). The exception is an intra-Community supply of goods: an advance on it does not make the tax chargeable, and the invoice, including one for the advance, is issued by the 15th of the month after the month of the tax event (Art. 25, para. 7 and Art. 113, para. 5). When the client is a non-taxable individual, an invoice is optional (Art. 113, para. 3, item 1), but the VAT on the advance still becomes chargeable on receipt.

The duty to invoice falls on every taxable person who supplies, not only on VAT-registered ones: an invoice is also issued "on receipt of an advance payment" (Art. 113, para. 1). If the invoice is late, the tax is due for the period in which it became chargeable (Art. 86, para. 2).

A full payment on the proforma before delivery is a 100% advance: the invoice for it is issued within 5 days of the payment, and once it has been issued, no new invoice need be issued at delivery (ППЗДДС Art. 79, para. 8). Partial advances, refunds and advances in foreign currency are covered in advance payment invoices in Bulgaria.

Payment on delivery after a proforma

When the client pays on or after delivery, the payment is not an advance, and the invoice is issued within 5 days of the tax event (Art. 113, para. 4 of the VAT Act). The tax event is the date ownership of the goods passes or the service is performed (Art. 25, para. 2), and VAT becomes chargeable on that date (Art. 25, para. 6, item 1). Neither the proforma date nor the payment date moves the deadline.

Example: proforma dated 2 November 2026, goods handed over and ownership transferred on 4 November, payment on 20 November. The invoice is due by 9 November 2026.

Example: a proforma for €3,000.00 plus VAT with a 50% advance

"Доставчик" ЕООД and "Клиент" ООД, both VAT-registered, agree on a marketing campaign for €3,000.00 excluding VAT: 50% in advance, the balance on acceptance.

The deal carries €3,000.00 of taxable amount and €600.00 of VAT, €300.00 each for October and November; the client deducts VAT on both invoices. Had the supplier relied on the proforma and issued one invoice on 6 November, the €300.00 of VAT on the advance would still be due for October (Art. 86, para. 2), and the October VAT return would be incomplete.

A proforma creates no accounting entry; entries follow payments and invoices. Account numbers are those common in practice; every business applies its own chart of accounts (Art. 11, para. 1, item 5 of the Accountancy Act).

Accounts: 503 current account, 411/412 customers and customer advances, 401/402 suppliers and supplier advances, 4531/4532 VAT on purchases and on sales, 602 external services, 703 service revenue.

What a proforma invoice should show

The law sets no required contents for a proforma invoice; they are a matter of practice. A good proforma carries the future invoice's data and clearly shows it is not an invoice.

The ten-digit sequence is explained in invoice numbering in Bulgaria, the required invoice details in Bulgarian invoice requirements, invoices to clients abroad in invoicing foreign and EU clients, and what invoicing software must do in free invoicing software in Bulgaria.

The proforma on the buyer's side

The buyer cannot deduct VAT or book an expense on a proforma invoice. Input tax credit requires a tax document under Arts. 114 and 115 of the VAT Act with the tax on a separate line (Art. 71, item 1). For an advance paid, the right arises when the tax becomes chargeable (Art. 68, para. 1, item 2 and para. 2) and is exercised on the advance invoice, in that period or one of the next 12 (Art. 72, para. 1).

A payment on a proforma is an advance, not an expense. What happens at delivery depends on what was bought:

• 01A service is recognised as an expense when received, under the accrual principle (Art. 26, para. 1, item 4 of the Accountancy Act).
• 02Goods for resale and materials for production are taken into inventory (материални запаси), a current asset (point 2 of the Bulgarian standard СС 2 on inventories). They become an expense when sold or used (IAS 2 Inventories, para. 34).
• 03Machinery or another long-term asset is capitalised and depreciated over its useful life.

Depreciation is covered in book vs tax depreciation in Bulgaria. If no advance invoice arrives within 5 days of payment, ask the supplier for one.

Common mistakes

• 01A proforma instead of an invoice for an advance received. VAT is chargeable on payment (Art. 25, para. 7), the invoice is due within 5 days (Art. 113, para. 4), and a late invoice does not move the tax to a later period (Art. 86, para. 2).
• 02A proforma numbered from the ten-digit invoice sequence, which must have no gaps (ППЗДДС Art. 78, para. 2).
• 03A proforma without the word "Проформа" that looks like an invoice. The buyer may enter it in the purchase ledger and deduct VAT it has no right to (Art. 71, item 1).
• 04The buyer books an expense on the proforma. The payment is an advance. At delivery a service becomes an expense (Art. 26, para. 1, item 4 of the Accountancy Act), while goods are taken into inventory and become an expense when sold or used (IAS 2, para. 34).
• 05A proforma that does not say whether the amount requested includes VAT. If the client transfers €1,500.00, VAT is included (Art. 25, para. 7): taxable amount €1,250.00, VAT €250.00.
• 06Holding the invoice until the proforma is paid after delivery has happened. The deadline runs from the tax event, not the payment (Art. 113, para. 4).

In smetni.app

smetni.app has no separate "proforma invoice" document. The sales document types are invoice, quote, debit note and credit note, all on every plan. When a client asks for a proforma before paying, you create a quote in the Sales module. A quote has its own reference number with the prefix "Q-", not one from the invoice sequence, and its own statuses: accepted, rejected and expired. An accepted quote with a client can be converted once into an invoice, which is created as a draft in the quote's book (кочан) and gets its ten-digit number when issued. After payment you issue the advance invoice, or the invoice for the supply when the client pays on delivery. See the Sales and Send and track guides.