Business Trips as a Deductible Expense in Bulgaria

What counts as a business trip

Business travel is one of the cleanest deductions a Bulgarian company has, and one of the most formalised. You cannot simply expense a trip against receipts: two regulations set the amounts and the paperwork. The Regulation on Domestic Business Trips (НКС) covers travel inside Bulgaria, the Regulation on Official Business Trips and Specialisations Abroad (НСКСЧ) covers travel out of it.

Not every journey qualifies. Art. 6(1) НКС excludes people whose work happens during the journey itself (drivers, flight and ship crews), tasks performed inside the town where the person's place of work is located, and roles such as couriers and delivery staff whose job is travel by nature.

The tax test is separate, and it is the one that usually fails. Under Art. 33(1) of the Corporate Income Tax Act (ЗКПО), travel and stay costs are recognised only when the trip relates to the company's activity and the costs are documented (Art. 10 ЗКПО). The regulation tells you how much you may pay; the tax act decides whether the National Revenue Agency (NRA) accepts it.

The travel order: the document founders always miss

There is no equivalent in most countries, which is why it gets skipped. Art. 8(1) НКС requires a written travel order issued in advance (заповед за командировка). It may be electronic under EU Regulation 910/2014, so a PDF signed with a qualified electronic signature works. Only in urgent cases may the trip start on a verbal instruction, and the written order must still follow within 3 days (Art. 8(2)).

Art. 9(1) НКС lists the contents: the company and the officer issuing it, the traveller's name and position, the destination, the task, the duration, the per diem, travel and accommodation amounts due, the mode of travel, the type of report expected, and whether the order needs countersigning on arrival. Any change of dates or terms needs a new written order (Art. 9(2)).

Two post-trip steps matter just as much: a report on the work performed within 3 days of returning, and the manager's comment within 5 (Art. 29(1)). Payment is made against the order, a copy of the report, and a statement of amounts due with the accommodation document, ticket and boarding pass attached (Art. 32). If you run the company remotely, make this a monthly routine rather than reconstructing it during an audit.

Domestic per diem: EUR 22 and the double-rate rule

Since 1 January 2026, Art. 19(1) НКС sets per diem at EUR 22 per day when the traveller stays overnight at the destination (published in State Gazette No. 115 of 30 December 2025). The previous lev-denominated amount worked out to roughly EUR 20.45, so this is a real increase, not a conversion. Without an overnight stay, per diem is 50%, or EUR 11 (Art. 19(2)). None is due for days spent returning to the usual workplace to report (Art. 19(3)), or when full free meals are provided at the destination (Art. 23).

Per diem needs no receipts. It is a flat amount for food, local transport and incidentals, which is exactly why it is capped. Art. 21(1) НКС lets the employer pay up to 200% of the base amount, so EUR 44 a day. That matches Art. 24(2)(5)(b) of the Personal Income Tax Act (ЗДДФЛ): per diem is excluded from taxable employment income up to double the amount set in a statutory act. So EUR 44 a day with an overnight stay and EUR 22 without it carries no income tax and no social contributions; anything above is taxable income and enters the insurance base.

Tax-free per diem appears in the annual Art. 73(6) ЗДДФЛ return only if it exceeds EUR 511.29 for the year. Any taxable excess is reported regardless of size.

Trips abroad: rates are set per country

Outside Bulgaria there is no single figure. Art. 15(1) НСКСЧ refers to Appendix No. 2, which sets per diem and accommodation limits per destination country, each in a specified currency. Those amounts were updated by Council of Ministers Decree No. 45 of 22 March 2023 (State Gazette No. 27 of 24 March 2023) after nearly 19 years unchanged, replacing a flat EUR 35 per diem and EUR 130 accommodation cap. For Germany, per diem is now EUR 56 and accommodation up to EUR 207; for Greece, EUR 43 and up to EUR 159. Check the current Appendix No. 2 before writing the order.

The abroad regulation carries reductions that are easy to miss:

• full board provided in kind by the host means only 30% of per diem is paid (Art. 20(1));
• if the host covers part of the costs, per diem drops by that share: lunch 35%, dinner 35%, other expenses 30% (Art. 18(3));
• a stay of under 24 hours in a neighbouring country earns 35% of that country's per diem, provided it exceeds 4 hours (Art. 21);
• the full rate applies for up to 30 consecutive calendar days, after which per diem is cut by 25% (Art. 22).

Management may set amounts different from the table but no more than double them (Art. 17(1)). Out of scope here: posting employees to a client's site in another EU country brings separate obligations, including an A1 certificate.

Travel and accommodation: documents, not flat rates

Travel money covers the journey to the task and back plus public transport inside the destination town (Art. 11 НКС), and the mode of transport is chosen by the employer and stated in the order (Art. 12(1)).

For a private car, Art. 13(1) НКС gives travel money equal to the value of the fuel consumed, using the manufacturer's consumption figures for combined driving. Art. 13(2) requires the order to state the car's type and make, its consumption, the fuel type and price, the route and the distances in kilometres. If others ride along, only the driver is paid (Art. 13(3)). Abroad, Art. 13(4) НСКСЧ offers a choice: 50% of the cheapest airfare to the same destination, or the fuel equivalent, plus tolls and parking.

Accommodation is reimbursed at the amount actually paid, taxes and fees included, against a properly issued document, capped at the approved amount per night, with no offsetting between nights (Art. 26(1) НКС). Free lodging means no allowance (Art. 27).

Tax treatment here is friendlier than for per diem: under Art. 24(2)(5)(a) ЗДДФЛ, travel and accommodation are excluded from taxable income when documented, with no statutory ceiling. No cap, but no forgiveness for a missing invoice. If the car is the company's rather than the traveller's, the rules differ: see company cars and deductible expenses, and for the wider logic of what the NRA accepts, which expenses are tax deductible.

Can the owner claim it? Manager vs shareholder

This matters most to a foreign founder, because trips to Bulgaria are often the company's main travel cost. What decides it is the capacity in which you travel, not whether you own the shares.

Art. 33(1) ЗКПО recognises travel and stay expenses of individuals in an employment relationship with the company or engaged under a non-employment relationship, including managers and members of management or supervisory bodies, where the trip relates to the activity and the costs are documented. Managers are named explicitly, even when the manager is also the sole owner.

Art. 33(2) draws the line: travel and stay of shareholders or partners travelling in that capacity is not recognised. Flying in to meet a client or inspect a site is a company expense; flying in for a general meeting as the owner is not. The NRA confirmed the same in letter No. 24-39-42 of 27 April 2016: it needs a legal basis (employment or non-employment relationship, including a management contract) and a connection to the activity.

On the personal income tax side:

• Manager with a management and control contract (ДУК). Treated as an employment relationship under § 1(26)(з) ЗДДФЛ, so Art. 24(2)(5) applies directly: documented travel and accommodation plus per diem up to double the rate, all tax free.
• Owner registered as a self-insured person taking remuneration for personal labour. Personal-labour relationships in your own company are likewise treated as employment under § 1(26)(и) ЗДДФЛ, so the same regime applies.
• Manager with no contract and no remuneration. Art. 13(1)(23) ЗДДФЛ applies instead: travel and accommodation under non-employment relationships are untaxed when borne by the principal and documented, as is per diem up to double the amount set for employees. Same EUR 44 ceiling.

One honest caveat. НКС was issued under Art. 215(1) and Art. 121 of the Labour Code, so by its letter it addresses employees. For an owner with no employment contract, the trip is authorised by internal company rules, and the regulation's amounts serve as the reference because the tax provisions point to the amount set in a statutory act. And if your usual place of work sits outside Bulgaria, take local advice first.

Why the NRA rejects business trip costs

Rejections almost always come from the paperwork, not the amounts:

• No order, or one dated after the trip. Art. 8(1) НКС requires it in advance, and the date is visible.
• A vague task. "Business meeting" with no client, site or objective fails the connection to the activity under Art. 33(1) ЗКПО.
• No report (Art. 29(1)) or a missing Art. 32 document, usually the hotel bill or the boarding pass.
• Per diem above the double rate where the excess was never taxed or added to the insurance base.
• Accommodation without a document, above the approved nightly amount, or offset between nights, which Art. 26(1) forbids.
• Travel inside the town where the person works, or a person caught by Art. 6(1) НКС.
• Trips that read as personal. Dates spanning a weekend with no task, resort destinations with no client, family travelling along.

The cost lands twice: a disallowed expense increases the company's taxable result and attracts corporate tax at 10% (Art. 20 ЗКПО), while per diem above the double rate becomes taxable personal income with contributions on top. Under § 6 НКС, the Labour Inspectorate, the NRA and the Public Financial Inspection Agency all have competence to ask for the file.

How FreeMe.bg helps

Business trips are one of the few expenses where the rules are unambiguous and the mistakes are purely administrative: a missing order, a missing report, a cap quietly exceeded. FreeMe.bg keeps the order, the receipts and the report together, checks that per diem stays inside the tax-free amount, and posts the numbers into your Bulgarian accounts, at a fraction of a traditional accountant's price.

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