Art. 97a VAT Registration: Buying Meta and Google Ads From a Bulgarian Company

How a €20 ad puts you in the VAT register

You set up a Bulgarian company, you keep it lean, you run your own marketing. You spend €20 on Facebook or Google Ads, get an invoice from Meta Platforms Ireland Limited or Google Ireland Limited, and hand it to your bookkeeper at month end. That's when you learn you were supposed to register for VAT before you paid.

The mechanism is standard EU reverse charge, but Bulgaria implements it in a way that surprises people. Advertising is a service, and for B2B services the place of supply is where the customer is established, so Bulgaria (Art. 21(2) of the Bulgarian VAT Act). The tax is payable by the recipient, not the supplier (Art. 82(2)(3)). An Irish supplier cannot remit Bulgarian VAT to the Bulgarian treasury, so the obligation lands on you.

That is what Art. 97a(1) is for: any taxable person receiving such services must register for VAT. There is no threshold here at all. It does not matter whether your turnover is €5,000 or €50,000, or whether the invoice is for €20 or €20,000. One service is enough. The National Revenue Agency (NRA) applies the same logic to hosting, SaaS subscriptions, Booking or Airbnb commissions, and EU freelancers' invoices. If a foreign supplier sold you a service, you are in scope.

The deadline runs backwards: 7 days before you pay

This is the part almost nobody gets right. The registration application must be filed no later than 7 days before the date the tax on the supply becomes chargeable, meaning before the advance payment or the tax event, whichever comes first (Art. 97a(4)). The clock runs backwards from the payment, not forwards from the invoice.

With Meta and Google, the payment is almost always the first event: your card is charged immediately or when you hit a billing threshold, and the document arrives afterwards. In practice, your application has to be in at least a week before you fund the ad account. If you have already paid, the deadline expired before you knew it existed.

You file with the NRA electronically at portal.nra.bg using a Bulgarian qualified electronic signature (KEP), or in person at your local NRA office. This is worth sorting out early if you manage the company from abroad, because the qualified signature itself takes time to obtain and you cannot file without it. The NRA completes an Art. 97a registration within 3 days of receiving the application, and the registration date is the date the registration act is served on you (Art. 103). Treat the filing as part of planning the campaign, not part of launching it.

What Art. 97a does not give you

Art. 97a is often called a partial registration, and the label is accurate. It hands you a VAT number and a set of obligations, but almost no rights:

• No input VAT deduction. A person registered under Art. 97a cannot deduct VAT on purchases (Art. 70(4)). The VAT you self-charge on your ad spend is a real cost, not a wash as it would be under a full registration.
• You still don't charge VAT to your own customers. A person registered under Art. 97a may not show VAT on the invoices it issues (Art. 113(9)). Your pricing and your sales invoices stay exactly as they were.
• It does not cover Art. 96. If you later cross the mandatory threshold, which since 1 January 2026 is €51,130 of annual turnover, you must register on that ground as well, within the normal deadlines.

So this is not "being VAT registered" in the sense a founder from Germany, the UK or the Netherlands would assume. A full registration under Art. 96 (mandatory, threshold-based) or Art. 100(1) (voluntary, no threshold) gives you deduction rights and puts VAT on your sales invoices. Art. 97a exists purely so the treasury can collect tax on services you bought abroad.

If your ad spend and other EU service costs are meaningful, a voluntary full registration is often the better answer: same self-charge, but you get the deduction back.

When you must register for VAT in Bulgaria →

You self-charge with a protocol under Art. 117

Once registered, you charge the tax to yourself. For each service received you issue a protocol under Art. 117, no later than 15 days from the date the tax became chargeable (Art. 117(3)). The rate is the standard 20%.

Example: €500 of Facebook ads in a month. You issue a protocol with a taxable base of €500 and VAT of €100. That €100 goes to the NRA and stays out of pocket, because there is no deduction. Your real ad cost is €600, not €500. Under a full registration the same €100 would be self-charged and immediately deducted, with zero cash-flow effect. That difference is the whole argument for weighing a voluntary full registration instead.

If you issue the protocol late, it must be reported in the ledgers for the period in which the tax became chargeable, not the period in which you issued it (Art. 126(3)(2)). A small detail that turns one slip into two.

How to issue an Art. 117 VAT protocol →

The monthly filings that come with it

Art. 97a is not a one-off form. From the registration date onwards you owe:

• A monthly VAT return under Art. 125, due by the 14th of the month following the tax period.
• A purchase ledger and a sales ledger, filed together with the return.
• Filing electronically with a qualified electronic signature, mandatory. Paper filing is not accepted except in narrow cases.

Returns are due for months with no activity at all. Spend €20 on ads in March and nothing afterwards, and you still file a nil return every month until you deregister. A missed return is a separate offence under Art. 179 even when the tax due is zero, which is the trap for founders who assume nil filings are optional.

A VIES return is only required when you supply services to taxable persons in other member states, not for the ads you receive.

What it costs if you miss the deadline

Filing the registration application late is an offence in its own right. Art. 178 provides for a penalty on the company (or a fine for an individual who is not a trader) of roughly €256 to €2,556. The figure in the statute is still written in the pre-euro national currency and converts at the fixed rate.

The unassessed tax is separate. Under Art. 180 the penalty equals the VAT you failed to charge, with a floor of about €256, doubled for a repeat offence with a floor of about €2,556. Late-payment interest runs on the tax itself. The NRA can also register you ex officio, with retroactive effect, and then assess everything backwards.

The arithmetic is often absurd: €40 of ads, €8 of tax, and several hundred euro of penalties. The administrative weight of Art. 97a is almost always larger than the tax it collects, which is exactly why so many small companies only discover the problem during an audit.

Add your VAT number to Meta and Google, and know how to exit

Registration gives you a BG-prefixed VAT number that is valid and verifiable in the EU VIES system. Put it in the billing settings of Meta Business and Google Ads. If you don't, the platforms may add VAT to your ad spend, because by default they treat accounts without a valid tax ID as non-business. You would then pay the tax twice: once to the platform and again by protocol to the NRA. Google states in its own help centre that with a valid ID you are responsible for self-assessing and paying VAT at your local rate.

Leaving the regime is not automatic. An Art. 97a registration stays live until you apply to end it. The ground is Art. 108(1)(4): optional deregistration when, at the date of the application, no grounds for mandatory registration exist. There is no minimum period you must stay registered first. But if you plan to run ads again next year, deregistering only to register again makes little sense. Treat the monthly returns as a fixed running cost and automate them.

How FreeMe.bg helps

FreeMe.bg tracks your VAT status, issues the Art. 117 protocols and files the monthly returns: for one company or five, from a single place, at a fraction of a traditional accountant's price. Upload the Meta or Google invoice, and the platform recognises the foreign supplier, self-charges the VAT and prepares the protocol and the ledgers. You don't have to remember the 15-day protocol window or the 14th of every month, and you don't need a Bulgarian accountant on the phone to explain reverse charge.

See how we handle VAT →
See how we automate invoicing →