In short: Selling from Bulgaria to the UK, Switzerland or Norway requires separate VAT and customs checks. Goods may qualify as zero-rated Bulgarian exports, while destination-country VAT can still apply. Check registration thresholds, export evidence and delivery terms before accepting orders.
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Selling to the UK, Switzerland or Norway from Bulgaria
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Selling to the UK, Switzerland or Norway from Bulgaria can create VAT obligations in two places. Your company must establish the Bulgarian treatment and check whether tax is collected at checkout or when the goods arrive.
This guide explains five practical checks for Bulgarian businesses. The UK goods examples concern Great Britain: England, Scotland and Wales. Northern Ireland has separate arrangements for goods, including transactions with the EU.
1. Separate Services from Goods and Check the VAT Rules
For services covered by the general B2B place-of-supply rule, a Bulgarian supplier normally does not charge Bulgarian VAT when the business customer is established in one of these destinations. Keep evidence of the customer’s business status and identify the relevant receiving establishment. The invoice should state the applicable legal basis, commonly Article 21(2) of the Bulgarian VAT Act.
This is a supply with a place of taxation outside Bulgaria, rather than a zero-rated export of goods. Exceptions apply, including certain property-related, admission and transport services. Consumer services also require a separate assessment, especially digital and remotely supplied services.
VIES and the EU OSS scheme do not replace local compliance for these destinations. Local reverse-charge or acquisition-tax rules may nevertheless apply. For goods involving Northern Ireland, check the special EU arrangements before treating the transaction as an ordinary export.
2. Keep Evidence for Zero-Rated Exports from Bulgaria
Qualifying exports of goods from Bulgaria to destinations outside the EU can be taxed at 0% Bulgarian VAT under Article 28 of the Bulgarian VAT Act. However, an overseas delivery address alone does not establish entitlement to that rate.
Keep the required export documentation, including the customs export record and confirmation of exit where applicable, the invoice and transport evidence. These records should identify the seller and goods and support the movement outside the EU. Ask your customs representative which documents will be supplied after dispatch.
- Match the commercial invoice to the shipment and customs records.
- Retain the export reference and evidence that the goods left the EU.
- Keep courier, freight and delivery records with the transaction.
- Check the documentation deadlines and any required VAT corrections.
Missing evidence can put the zero rate at risk and require Bulgarian VAT to be accounted for under the applicable rules. For standard-rated goods, that exposure can be 20%. Collect the documents regularly instead of waiting for a tax review.
3. Check the UK VAT Rules Before Shipping to Great Britain
For direct consumer sales of goods dispatched from Bulgaria to Great Britain in consignments with an intrinsic value of £135 or less, the overseas seller generally registers for UK VAT and accounts for it at the point of sale. The standard rate is 20%, although the product may qualify for another rate.
The £135 limit applies to the whole consignment, rather than each item. Separately stated transport and insurance costs are normally excluded when testing intrinsic value. Marketplace sales and sales to customers supplying a valid UK VAT number have different rules.
Above £135, normal import VAT and customs procedures apply. Who pays depends on the import arrangements. A seller importing in its own name may also have UK VAT obligations. See HMRC’s guidance for overseas sellers.
Shipping from Bulgaria does not automatically make goods EU-originating. Preferential duty relief depends on meeting and proving the relevant origin rules. Otherwise, the normal tariff applies, which may itself be zero for some goods. Confirm the origin requirements before promising duty-free delivery.
4. Monitor Norway’s VOEC Threshold and Item Values
Norway’s VOEC scheme covers eligible consumer goods valued below NOK 3,000 per item. Registration is required at the latest when relevant taxable consumer sales reach NOK 50,000 in a rolling 12-month period. This is not simply a calendar-year test.
Shipping is excluded when testing the item threshold but included in the VAT calculation. The standard rate is 25%. Food, excise goods and restricted products are excluded from VOEC. Items valued at NOK 3,000 or more follow normal import procedures. Check the Norwegian Tax Administration’s registration guidance.
Provide the VOEC number electronically to the carrier. Incorrect shipment data can lead to delays or a second VAT charge at import. Check the carrier’s electronic reporting requirements when setting up courier integrations.
5. Check Switzerland’s Mail-Order VAT Registration Rules
Swiss mail-order registration can arise when annual turnover from qualifying small consignments reaches CHF 100,000. These are consignments for which import VAT is not collected because the calculated tax is CHF 5 or less. The standard Swiss VAT rate is 8.1%; reduced rates apply to some goods.
Under these rules, from the following month all the seller’s shipments from abroad to Switzerland are treated as domestic supplies, including larger consignments. The seller must register, import in its own name and appoint a Swiss tax representative. Import VAT recovery depends on the applicable conditions.
Before this registration applies, larger consignments generally follow normal import taxation. Marketplace rules can also affect who accounts for VAT. Check the Swiss Federal Tax Administration’s mail-order guidance.
VAT and Customs at a Glance
| Destination | Key threshold | VAT treatment for consumer goods |
|---|---|---|
| Great Britain | £135 or less per consignment | For qualifying direct sales, the overseas seller normally collects UK VAT at checkout. Above £135, normal import rules apply. The standard rate is 20%. |
| Norway | Below NOK 3,000 per eligible item; NOK 50,000 registration threshold over 12 months | VOEC-registered sellers collect VAT at checkout on eligible goods. Items at or above NOK 3,000 follow normal import procedures. The standard rate is 25%. |
| Switzerland | CHF 100,000 annual turnover from qualifying small consignments | Once mail-order registration applies, all shipments from abroad to Switzerland become domestic supplies, including larger consignments. The standard rate is 8.1%. |
These are the main consumer-goods rules. Reduced rates, excluded products, marketplace arrangements and other registration obligations may change the treatment. Northern Ireland has separate rules for goods. See the country sections above for details.
Who Pays Import VAT Under DDP and Other Delivery Terms?
Under DDP, the seller takes responsibility for import clearance and the relevant duties and taxes under the agreed terms. Confirm that your company can fulfil the importer obligations and whether local VAT registration or representation is needed. A DDP label alone does not establish the right to recover import VAT.
Under arrangements such as DAP, the buyer normally handles import clearance and pays import charges. Couriers may also charge clearance fees. Explain these costs before payment to reduce delivery disputes and refused parcels.
Practical Example: A Bulgarian Shop Selling to Manchester
Assume your Bulgarian online shop sells directly to a consumer, dispatches from Bulgaria and offers standard-rated adult clothing. A €90 jacket falls below £135 at the applicable exchange rate. UK VAT is therefore normally collected at checkout, even where the delivery terms leave other import responsibilities to the buyer.
A €400 coat exceeds the threshold. Under normal import arrangements with the customer as importer, import VAT is collected on arrival. Twenty per cent of €400 is €80, but the actual import VAT may be higher because the taxable amount can include shipping and duty. The courier may add a fee.
For both sales, the Bulgarian export treatment must be assessed separately. A qualifying export can carry 0% Bulgarian VAT when the required evidence is retained. Collecting tax in the destination does not remove your Bulgarian documentation obligations.
What Should You Check Before Selling Outside the EU?
- Whether you sell goods or services and whether the customer is a business or consumer.
- The destination, product classification and applicable VAT rate.
- Consignment values, item values and local registration thresholds.
- Who will be the importer and who pays border charges.
- Which export, origin and shipping records you must retain.
- Whether a marketplace collects tax on your behalf.
Selling to the UK, Switzerland or Norway is easier when your checkout, delivery terms and accounting records follow the same approach. Review each destination before launching sales, then monitor turnover and shipment values as orders grow.
ASB Accounting Services Bulgaria can help review Bulgarian VAT treatment, export records and the accounting implications of cross-border sales. Contact our team to discuss your arrangements and identify where destination-country specialist support is needed.
Takeaways
- Bulgarian export VAT and destination-country VAT are separate checks.
- Great Britain’s low-value rule uses a £135 consignment threshold.
- Norway’s VOEC value limit applies per eligible item.
- Swiss mail-order registration can cover both small and larger shipments.
- Clear delivery terms and complete export records help prevent avoidable costs.
Does zero-rated Bulgarian VAT mean the customer pays no VAT?
No. Destination-country VAT can still apply at checkout or import.
Can EU OSS cover sales to these destinations?
OSS does not cover ordinary exports to Great Britain, Switzerland or Norway. Goods involving Northern Ireland require a separate assessment.
Does DDP automatically require a local VAT number?
Check the destination’s rules and the actual importer arrangements. DDP allocates delivery obligations, while VAT registration follows local tax law.
This article provides general information and does not constitute tax, accounting or legal advice. Each situation is different and should be reviewed individually under the legislation applicable at the relevant time.