Art. 117 protocol in Bulgaria: Google Ads, Meta, AWS, Stripe

Invoices for Google and Meta ads, AWS and Stripe fees usually arrive without VAT. On the ads and AWS the VAT is still due: the tax is chargeable to you as the recipient, and you charge it yourself with a protocol under Art. 117 of the Bulgarian VAT Act (ЗДДС). Stripe payment processing fees are usually exempt, but they too get a protocol, without tax.

When is an Art. 117 protocol issued

A VAT-registered business issues an Art. 117 protocol when the tax is chargeable to it as the recipient rather than to the supplier (Art. 117, para. 1, item 1 with Art. 82, paras. 2-6 and Art. 84 of the VAT Act). For services, the usual case is:

• 01You are a taxable person, so the place of supply is where you are established: Bulgaria (Art. 21, para. 2 of the VAT Act).
• 02The supplier is not established in Bulgaria, whether it is in another member state or outside the EU (Art. 82, para. 2).
• 03The service is taxable, so the tax is chargeable to the recipient (Art. 82, para. 2, item 3).

A protocol is also issued for an exempt service: Art. 81, para. 6 of the regulation implementing the VAT Act (ППЗДДС) requires one "for a supply with its place of supply in Bulgaria on which no tax is to be charged". That is usually the case for payment processing fees, exempt under Art. 46, para. 1, item 3 of the VAT Act.

What the protocol contains

An Art. 117 protocol must contain the elements in Art. 117, para. 2 of the VAT Act:

• 01Number and date.
• 02The name and VAT number of the recipient issuing the protocol.
• 03The type of service.
• 04The date of the tax event.
• 05The taxable amount and the VAT rate.
• 06The legal basis for charging or not charging the tax, for example Art. 82, para. 2, item 3 of the VAT Act.
• 07The amount of tax.
• 08The supplier's VAT number when it is registered in another member state, and the invoice number and date if the invoice was issued by the date of the protocol.

You do not have to wait for the invoice: if it is issued after the protocol, its number is not entered.

When the tax becomes chargeable and what the deadline is

The protocol is issued no later than 15 days after the tax became chargeable (Art. 117, para. 3 of the VAT Act). The tax becomes chargeable on the date of the tax event (Art. 25, para. 6), which depends on the service:

If you top up an ad account in advance, check with your accountant whether the payment is an advance under Art. 25, para. 7.

A protocol issued on time belongs to the tax period in which it is issued; if the deadline is missed, the tax is due for the period in which it became chargeable (Art. 86, para. 2). The protocol then goes into both ledgers for that period, and the National Revenue Agency (НАП) is notified in writing under Art. 126, para. 3, item 2 of the VAT Act (Art. 81, para. 5 of the regulation).

For an invoice in another currency, the taxable amount is set in euro at the latest European Central Bank rate at the moment the tax becomes chargeable (Art. 26, para. 6).

How the protocol is numbered

Protocols have a numbering rule separate from that for invoices: numbers ascend without duplicates or gaps, all copies carry the same number and the numbering does not restart at year end (Art. 80, paras. 2 and 3 of the regulation). The ten-digit requirement in Art. 78, para. 2 applies to invoices and their notes; Art. 80 sets none for protocols.

The supplier's invoice number is not the protocol number. It is entered as a separate element (Art. 117, para. 2, item 9 of the VAT Act).

How the protocol goes into the ledgers and the VAT return

The protocol goes into both the sales ledger and the purchase ledger, so the tax and the credit land in one VAT return.

• 01Charging: the sales ledger (Art. 86, para. 1, item 3), taxable amount in column 14 and tax in column 15 (annex 10 to the regulation); cells 12 and 22 of the VAT return.
• 02Input tax credit: the right arises when the tax becomes chargeable (Art. 68, para. 2) and is exercised with the issued protocol (Art. 71, item 2) for that period or one of the next 12 (Art. 72, para. 1). Purchase ledger columns 10 and 11 (annex 11); cells 31 and 41 of the VAT return.
• 03Document type in both ledgers: code 09, "Protocol or other document" (annex 12 to the regulation).

Full credit applies when the service is used for your taxable supplies (Art. 69, para. 1). If it also serves exempt supplies, the credit is partial (Art. 73), and in the cases in Art. 70 there is none.

For an exempt service the protocol carries no tax. According to a National Revenue Agency opinion (ref. 53-04-296 of 28 May 2018), it goes into sales ledger column 14 with zero in column 15, and into purchase ledger column 9, for supplies without credit or without tax. In the VAT return these are cells 12 and 30.

No VIES return is filed for services received: Art. 125, para. 2 of the VAT Act requires one only for supplies made.

Google Ads, Meta, AWS and Stripe: what goes on the protocol

Google and Meta ads, AWS and foreign SaaS go on the protocol with 20% VAT; Stripe payment processing fees are usually without VAT. The entity, and whether the supplier charges VAT, come from the suppliers' own pages. Whether a service is taxable or exempt is decided under the VAT Act.

Documenting Stripe sales and the monthly fee invoice is covered in Stripe and the Bulgarian invoice.

If the business is not VAT-registered

A business without VAT registration that receives taxable services, with their place of supply in Bulgaria, from a supplier not established there must register under Art. 97a, para. 1 of the VAT Act. The provision sets no turnover threshold.

• 01The application is filed no later than 7 days before the tax becomes chargeable, that is before the advance or the tax event (Art. 97a, para. 4).
• 02A business registered under Art. 97a charges the tax with a protocol and files a VAT return for every month (Art. 125, paras. 1 and 4).
• 03It has no right to input tax credit (Art. 70, para. 4), so the 20% VAT is a real cost.
• 04Exempt services do not trigger registration: Art. 97a, para. 1 covers only taxable services. Stripe payment processing fees alone do not create the obligation.

Example: a monthly Google Ads invoice of €1,000.00

A VAT-registered company advertises on Google Ads with monthly invoicing. Its September 2026 spend is €1,000.00. For the example we assume the account terms make September's payment due on 30 September 2026, so that is the tax event (Art. 25, para. 4). The Google Ireland Limited invoice arrives by email on 2 October.

The protocol of 5 October is on time, so it belongs to October (Art. 86, para. 2). If you issue it on 30 September, both entries go into September. The net effect is zero only with full input tax credit.

The 30 September date is an assumption. The National Revenue Agency applies Art. 25, para. 4 to periodic supplies with Google too: each month is a separate supply, and the tax event is the date on which the payment for the month falls due under the contract (opinions of the NRA Plovdiv office of 2 September 2022 and of the NRA central office of 22 July 2015). Google says payment terms on monthly invoicing are typically 30 days after the invoice, so under standard terms the payment for September falls due about a month after the invoice, not on 30 September. Take the date from the payment terms of your account.

Common mistakes

• 01Waiting for the invoice. The 15 days run from when the tax becomes chargeable (Art. 117, para. 3), not from receipt of the invoice. If payment became due at month end and the invoice arrives within five working days of the next month's start, part of the deadline is already gone.
• 02Issuing no protocol for an exempt service. Stripe payment processing fees carry no VAT, but a protocol is still issued (Art. 81, para. 6 of the regulation).
• 03Using the supplier's invoice number as the protocol number. The protocol carries your own number from your protocol series (Art. 80, para. 2 of the regulation); the invoice number is a separate element (Art. 117, para. 2, item 9).
• 04Entering the protocol in one ledger only. Without the purchase ledger you pay €200.00 with no credit for the period; without the sales ledger you claim credit for tax never charged.
• 05Converting at the rate on your bank statement. The rate is the latest ECB rate at the moment the tax becomes chargeable (Art. 26, para. 6).

In smetni.app

In the Purchases module (Pro plan and up) you can record an expense document of the type "Protocol (art. 117)". The protocol carries your own sequential number, and the supplier's invoice number goes in the note. When you choose this document type, lines without a rate get 20% self-charged VAT. Confirm with your accountant how to record a protocol without tax, such as for Stripe payment processing fees. If you buy advertising on Google or Meta for clients, see also smetni.app for marketing agencies. See the purchases guide and plans and pricing.