We connect customs declarations, supplier invoices, freight charges and import VAT with your accounting records and periodic reporting.
A Bulgarian importer came to ARG with the least confidence in the import and customs side of its accounting. ARG reviewed the records, revised the checklist against Bulgarian requirements, and coordinated the related accounting and filings. The result was a single, consistent set of steps instead of instructions that had to be reconciled from different people.
That distinction matters because an EORI number, a VAT number and a customs declaration serve different purposes. Import VAT also requires the right document trail and accounting period, while the choice between customs assessment and self-accounting must be checked before relying on the alternative route. This service connects the customs file with the VAT and accounting work that follows.
ARG can help when you need to
Confirm the legal entity named as importer, its EORI and VAT status, and whether the customs representative acts directly or indirectly.
Provide a precise product description, tariff classification, origin evidence, invoice and delivery terms, including freight and insurance.
Obtain the released declaration and proof of payment or valid self-accounting; a supplier invoice alone does not establish import VAT credit.
Check eligibility before using a special regime and budget current duties, including the July 2026 low-value e-commerce changes.
Import accounting connects customs clearance to the company’s stock, supplier balances and VAT records. EORI identifies the operator to customs, a VAT number records tax registration, and the customs declaration places the goods under the requested procedure. Confirm the importer and representative before dispatch, then arrange for the final declaration, valuation and tax evidence to reach accounting when the goods are released and physically received at the warehouse.
Article 9 of the Union Customs Code requires economic operators to register for customs purposes. EORI stands for Economic Operators Registration and Identification: one number identifies the operator across the EU customs system. An EU-established business normally registers in its state of establishment; a number already issued by another Member State should be checked before applying again. EORI does not grant product authorisation or a VAT deduction. Before shipment, confirm which legal entity is buying, which entity will be named as importer, and whether the broker will act directly in that entity’s name or indirectly in its own name.
A Bulgarian VAT number does not replace EORI, because VAT registration answers a tax question, while EORI answers a customs-administration question. A company can be VAT-registered and still need to arrange EORI before it can move through customs in Bulgaria. Likewise, having an EORI number does not itself prove that the importer is entitled to a VAT deduction or that the customs declaration is correct.
The customs declaration is the operative customs filing. Under the Union Customs Code, Regulation (EU) No 952/2013, the declarant is responsible for the accuracy, completeness and authenticity of the data and supporting documents. So the declaration is not just a form. It is the document that carries legal risk if the data do not match the shipment, the invoices, or the import status of the parties involved.
If you are preparing an import into Bulgaria, the usual order of analysis is this.
If one of these pieces is missing, the problem is different. A missing EORI number is a customs registration problem. A missing VAT number is a tax registration or accounting problem. A defective customs declaration is a clearance and liability problem. ARG’s role in this service is to help you identify which of those three issues exists before the shipment reaches the border formalities, so you do not treat a customs filing problem as if it were only an accounting entry.
The documents that must be checked before customs clearance fall into two groups. One group supports customs registration and the declaration itself. The other group supports the import VAT treatment and the accounting entry that follows the clearance.
Articles 20–24a of Bulgarian OrdinanceH-9 distinguish the registration routes. For Bulgarian-established operators within Article 20(1), Article 22a provides issuance on request at a customs office or through the relevant customs decision process, with identity data obtained from Bulgarian registers. Other qualifying applicants use the electronic or paper routes under Articles 21–22. A representative must prove authority. For a non-EU legal person, prepare the required recent registration documents and legalised Bulgarian translation. Establish the correct category before arranging a signature or form; the electronic customs-access registration and the EORI identifier serve related but separate functions.
For the customs declaration itself, the Union Customs Code places responsibility on the declarant for the accuracy, completeness and authenticity of the data and the supporting documents. That makes document review a legal-risk control, not a bookkeeping convenience. The practical point is simple. If the invoice says one seller, the transport papers show a different consignee, or the customs code is inconsistent with the goods, the declaration risk belongs to the person lodging it. Union Customs Code
A useful pre-clearance review normally looks at the following categories.
For applications under Articles 21–22, Article 24 of OrdinanceH-9 provides issuance after verification and no later than three working days from application. Discrepancies trigger instructions with a seven-day response period; ignoring them can terminate the procedure, while insufficient additional evidence can suspend it. Article 24a provides immediate issuance for the Article 22a route. Keep the request and contact details available to the person who can answer customs. A planned delivery date does not cure an incorrect company identifier, and an EORI application is not proof that the goods themselves have been released.
The practical distinction matters. A defect in the EORI form can suspend the registration process. A defect in the customs declaration can create customs liability at clearance. The two are related, but they are not the same failure. In a real import file, ARG would review both layers together so that the importer is not told only that the accounting is ready when the customs file still contains a mismatch that could interrupt the release of goods.
Tell us where you live, how your business works and what you want to change. We will help you identify the questions to resolve and the next steps to consider.
Import VAT and customs duty are separate charges. The NRA explains that the Bulgarian import VAT base includes customs value plus the relevant duties, taxes and incidental costs under Article 55. The standard VAT rate is 20%, with reduced rates or exemptions only where their conditions apply. The supplier’s invoice total may therefore differ from the import VAT base. Ask the customs representative for the declaration, valuation calculation and payment or accounting evidence, and identify freight, insurance and other additions separately before reconciling the shipment to stock and tax records.
The alternative route works differently from ordinary customs payment. Under the amendment to Article 57, if the importer qualifies under Article 167a, import VAT under Article 16 may be self-accounted for the tax period in which the taxable event under Article 54 arises, on the taxable base under Article 55, by using a protocol. That means the VAT is not treated as a simple border payment. It becomes part of the importer’s periodic VAT compliance and accounting. Amendment text
What matters commercially is the cash-flow and control difference. If you go through customs in the ordinary way, the VAT is assessed at clearance by the customs authorities. If you use the deferred-accounting route, the VAT is reflected in the VAT return for the relevant period instead. For an importer, that can change the timing of payment and the way the accounting file is prepared, but it does not remove the need for strict document control.
Article 167a’s postponed-accounting route is restricted by the goods listed in Annex 3, the statutory customs-value condition for each declared item, registration under Article 96 or Article 100(1) for at least six months, and the absence of due unpaid public liabilities collected by the NRA. The importer elects the treatment in the customs document under Article 167b and accounts for VAT through the required protocol and return. Give the broker the commodity classification, item values, registration basis and date, and debt-position evidence before clearance. A general VAT number or an EORI number alone does not establish eligibility, and the treatment should not be copied from another country’s postponed-VAT system.
A useful rule of thumb is this.
The safe decision point is eligibility first, accounting treatment second, and customs filing third.
That sequencing matters because an incorrect assumption about the route can affect both the customs file and the VAT return. The service is therefore not just about entering a number. It is about choosing the correct legal mechanism before the goods are cleared.
For ordinary import VAT deduction, the NRA requires the relevant customs document naming the claimant as importer and the required payment of import VAT, alongside the substantive conditions for input credit. The company’s VAT-registration basis and intended business use also matter. A commercial invoice naming your company as buyer cannot replace a customs document naming another importer. Obtain the final released declaration and evidence of the tax treatment, then reconcile them to the supplier invoice and stock receipt before claiming a credit.
The self-accounting route has its own evidence requirements. Articles 57(5–6), 71(10) and 167b link it to the customs document naming the importer, correct self-assessment and the general conditions for deduction. This must be distinguished from the special arrangements under which postal or courier operators collect import VAT from recipients. A restriction associated with one special mechanism should not be applied to every form of postponed import VAT. Record the precise legal basis, declaration reference and protocol, so the purchase and sales records reflect the actual regime used for the shipment.
This is why customs review and VAT posting cannot be separated in an import file. If the customs document names a different person, omits the importer identification, or contains a mismatch that breaks the evidence chain, the VAT deduction position becomes weaker. The accounting entry may still be possible in form, but the evidential basis is no longer clean.
The timing rule also matters. Under the VAT Act provision on import tax events, VAT becomes chargeable on the date when the customs-duty obligation arises, or would arise even where the duty is zero. If no customs-duty obligation arises, the taxable event occurs when the customs formalities are completed. That timing determines which VAT period the import belongs to, and therefore which return and ledgers must capture it. Current VAT Act text
The VAT chargeable period and the period in which an eligible input credit is exercised are related but not identical questions. Check the customs event first, then the applicable deduction window and documentation. Ordinary input credit can generally be exercised in the period it arises or one of the next twelve periods, subject to the statutory conditions. A document received after clearance should be logged with its receipt date and reviewed under the relevant rules; it should not automatically be treated as a lost credit or silently backdated into a closed return.
ARG would normally test three things together.
If one of those elements is missing, the file should be corrected before the return is finalised. In an import case, period matching is not a technicality. It is what keeps the customs document, the VAT ledger and the return in the same legal story.
ARG’s role in this service is the preparation work and review work that makes the import file usable for customs and VAT compliance. The importer still remains responsible for the underlying commercial truth of the shipment, but ARG helps organise the evidence, test the documents and coordinate the accounting treatment so the file is consistent before filing.
For low-value e-commerce imports, update any assumption that goods up to€150 enter duty-free. Regulation 2026/382 removed that relief from 1 July 2026. The Commission’s current guidance explains the temporary€3 duty per tariff item, rather than one charge per parcel or per physical unit, with specified preferential-treatment exceptions. IOSS concerns VAT and does not by itself remove this duty. Agree who declares and pays the customs charge, retain its calculation and keep it separate from VAT and the courier’s own fee when checking the landed cost.
That means ARG can prepare the EORI package, but the legally effective registration still depends on the proper signed submission and on the authority accepting the data. ARG can also review the customs declaration for internal consistency, yet the declarant remains responsible under the Union Customs Code for the accuracy, completeness and authenticity of the data and supporting documents. Union Customs Code
For the recurring VAT side, the National Revenue Agency states that the regular VAT return is filed by all VAT-registered persons together with the purchase and sales registers for the relevant tax period. If the period also includes intra-EU supplies or certain services, a VIES return may be required as well. That is why import posting and monthly VAT filing are related but not identical tasks. Import posting is the accounting treatment of a shipment. The VAT return is the periodic statutory filing that reports the tax position for the period. NRA filing guidance
In a practical client file, ARG would normally ask for the importer’s identity data, VAT status, customs papers, invoice, transport documents and the planned clearance sequence before the shipment moves. That allows the team to decide whether the issue is simply a bookkeeping entry, an EORI correction, a customs-declaration inconsistency or a VAT-period problem. For an importer, that distinction is decisive because the wrong fix at the wrong stage can leave the border file and the VAT file out of sync.
The practical implication is simple. Before the shipment proceeds, the client should decide whether the available documents support a clean customs filing and a defensible VAT position. If they do not, ARG’s next step is to correct the evidence chain first, because once the customs declaration is lodged, the legal risk shifts from planning to filing.
Compare the related procedures in this category, including their requirements and the stage at which you need them.
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