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How to Issue Invoices Correctly in Bulgaria: VAT Rules and Common Mistakes?
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Issuing an invoice may look like a routine administrative task. In practice, a small error can affect your VAT reporting, delay a payment or create problems during a tax inspection. The invoice must reflect the real transaction. Its dates, customer details, description and VAT treatment should match the contract, payment records and supporting documents. This guide explains how to issue invoices correctly in Bulgaria, which details to include and what to do when a mistake has already been made.
Issue the Invoice Within the Correct Deadline
Under the Bulgarian Value Added Tax Act, an invoice is generally issued no later than five days after the taxable event. The taxable event is usually the date on which the goods are delivered or the service is completed. If an advance payment is received before the supply takes place, the five-day period normally starts from the date on which the payment is received.
Different rules apply to certain cross-border transactions. For an intra-Community supply of goods, the invoice must generally be issued by the fifteenth day of the month following the month in which the taxable event occurred.
Do not choose an invoice date only because it is convenient for your monthly accounting. First identify:
- The date on which the goods were delivered.
- The date on which the service was completed.
- The date on which an advance payment was received.
- Whether special rules apply to the transaction.
A common mistake is to use the payment date for every invoice. Payment and supply dates are not always the same, so the correct deadline must be determined for each transaction.
Include All Mandatory Invoice Details
Bulgarian legislation does not require one official invoice template. A business may use accounting software or its own document design. The document must, however, contain the required information.
A standard invoice should include:
- The title “Invoice”.
- A unique ten-digit number written in Arabic numerals.
- An invoice number sequence without gaps or repeated numbers.
- The date of issue.
- The legal name and address of the supplier.
- The supplier’s identification number and VAT number, where applicable.
- The legal name and address of the customer.
- The customer’s identification number and VAT number, where applicable.
- A clear description of the goods or services.
- The quantity of the goods or the scope of the service.
- The date of the supply or advance payment, when different from the issue date.
- The unit value, taxable amount, applicable VAT rate and VAT amount.
- The total amount payable.
- Any discount that is not already included in the taxable amount.
- The legal reason for not charging Bulgarian VAT, where relevant.
Use the customer’s registered legal name rather than a brand name, website name or informal trading name. The description should also explain what was actually supplied. General wording such as “consulting”, “services” or “goods” may be too vague when used without further detail.
Determine the VAT Treatment Before Creating the Invoice
Do not automatically charge Bulgarian VAT simply because your company is established or VAT registered in Bulgaria.
The correct treatment depends on several facts:
- Whether you supply goods or services.
- Whether the customer is a business or a private individual.
- Where the customer is established.
- Whether the customer has a valid VAT number.
- Where the goods are transported.
- Where the service is considered to be supplied.
- Whether a special VAT rule applies.
For many business-to-business services supplied to a VAT-registered company in another EU country, Bulgarian VAT is not charged. The customer normally accounts for VAT through the reverse charge procedure.
In such a case, the invoice should normally include the customer’s valid VAT number, the wording “Reverse charge” and the applicable legal basis. Some services follow special place-of-supply rules, so the general business-to-business rule should not be applied without checking the nature of the service.
An intra-Community supply of goods may also be invoiced without Bulgarian VAT when the legal conditions are met. A valid EU VAT number alone is not enough. The supplier must also be able to demonstrate that the goods were transported from Bulgaria to another EU member state.
Use the Correct Legal Basis
An invoice without Bulgarian VAT should explain why VAT has not been charged. Writing only “zero VAT” or leaving the VAT field empty may not provide enough information.
The invoice may need to state:
- That the reverse charge mechanism applies.
- That the transaction is an intra-Community supply.
- That the supply is zero-rated.
- That the supply is VAT exempt.
- That the supplier is not required to charge VAT under a specific rule.
The legal basis must match the actual transaction. A reverse charge transaction is not automatically the same as a zero-rated or exempt supply. These treatments can have different reporting and documentation requirements.
Check the Customer Before Sending the Invoice
Customer verification should take place before the invoice is issued, not after it has been included in the accounting records. For a Bulgarian company, compare the provided details with the official company information. For a customer in another EU member state, check the VAT number through the European Commission’s VAT Information Exchange System, known as VIES.
Keep evidence of the check. A saved or printed validation result can support your position during a later review. VIES results are based on national VAT databases and may occasionally be temporarily unavailable or delayed.
Your verification process should confirm:
- The legal company name.
- The registered address.
- The identification number.
- The VAT number.
- The country in which the customer is established.
- Whether the VAT number is valid for intra-EU transactions.
Common Invoice Situations and What to Check
| Situation | What to Check | Common Mistake |
|---|---|---|
| Local Bulgarian transaction | Supply date, VAT status and applicable rate | Using the payment date as the supply date |
| Service to an EU business | Customer status, VAT number, place of supply and exceptions | Applying reverse charge without verifying the customer |
| Goods sent to another EU country | VAT number and evidence of transport | Relying only on a valid VAT number |
| Advance payment | Date the payment was received and invoice deadline | Waiting until the final supply to issue a document |
| Incorrect issued invoice | Type of error and whether the invoice was reported | Editing the original document manually |
Correct Invoice Errors Properly
Do not edit, overwrite or add information to an invoice after it has been issued. Bulgarian VAT rules do not permit corrections or additions to an existing invoice. If the document contains incorrect customer details, dates, descriptions or VAT treatment, it normally has to be cancelled and replaced with a new invoice.
If the incorrect document has already been included in the accounting registers of the supplier or the customer, a cancellation protocol is generally required. The protocol should identify the cancelled document, explain the reason for cancellation and refer to the replacement document.
A cancellation is not the correct solution when the original transaction was properly invoiced but later changed. In that situation:
- A debit note is generally used when the taxable amount increases.
- A credit note is generally used when the taxable amount decreases.
- A credit note may also be required when the transaction is cancelled.
The note is normally issued within five days of the event that caused the change.
Do Not Treat a Proforma as a Final Invoice
A proforma invoice is a preliminary commercial document. It may be used to request payment, confirm an order or provide transaction details before the official invoice is issued. It is not a VAT invoice and does not normally provide a basis for deducting input VAT. When an advance payment is received or the supply takes place, an official invoice may still be required within the applicable deadline. Keep the proforma number sequence separate from the official invoice sequence. This reduces the risk of treating a preliminary document as an accounting document.
Remember Bulgaria’s Official Currency
Bulgaria adopted the euro as its official currency on 1 January 2026. Invoices issued from that date should be accounted for in euro in accordance with the applicable accounting and tax reporting rules. Businesses should make sure that their invoice software, accounting records, document templates and internal procedures use the correct currency. Historical invoices should not be rewritten simply because Bulgaria changed its official currency.
Final Check Before Sending an Invoice
Before sending the document to your customer, confirm that:
- The invoice number is unique and follows the correct sequence.
- The issue date and supply date are accurate.
- The supplier and customer details are complete.
- The description matches the contract and actual supply.
- The VAT treatment has been reviewed.
- The correct legal basis is included where VAT is not charged.
- The customer’s EU VAT number has been checked when relevant.
- The invoice matches the payment and supporting documents.
- The document is recorded in the correct accounting period.
Correct invoicing is not only about completing a document. It is about creating a clear connection between the commercial agreement, the actual supply, the payment and the tax treatment.
ASB Accounting Services Bulgaria supports local and international businesses with accounting, VAT compliance and transaction reviews. Professional advice before an invoice is issued can be far simpler than correcting an incorrect VAT treatment later.
This article provides general information and does not constitute individual tax, accounting or legal advice. VAT treatment depends on the facts of each transaction and should be reviewed separately.
