VIES reporting for relevant EU supplies and Intrastat declarations for goods movements, including VAT number checks and transaction-data reconciliation.
A client felt least confident about VIES and Intrastat within its Bulgarian accounting. ARG reviewed the existing records and organised the reporting and filing steps around the applicable requirements.
The resulting checklist gave the people involved the same instructions and helped the client keep track of the work. The practical starting point was to establish which records supported each reporting obligation.
ARG can help you
Provide your VAT-registration basis and identify qualifying EU supplies. VIES is not a report of every foreign invoice or every purchase from the EU.
Track arrivals and dispatches independently against the annual Intrastat thresholds. Previous-year volumes and current-year growth can create different start dates.
Intrastat requires reliable goods codes, quantities and movement data; VIES treatment also needs the relevant customer and transaction evidence.
Arrange electronic filing access and a monthly data cut-off. Check the first-period Intrastat deadline, subsequent filing dates and processing results.
VIES and Intrastat report different aspects of cross-border business. VIES is the VAT Information Exchange System: a Bulgarian VIES return reports specified supplies to identified customers in other EU Member States. Intrastat records qualifying physical movements of goods between Bulgaria and other Member States once the relevant reporting obligation arises. A company can need one return without needing the other. The customer’s address, an invoice headed “EU sale” or an existing VAT number is not enough to decide.
Under Article 125 of Bulgaria’s VAT Act, the principal cases include intra-Community supplies of goods, qualifying intermediary transactions in a triangular operation, and specified business-to-business services taxable in another Member State under the general customer-location rule. An intra-Community supply ordinarily involves goods dispatched or transported from one Member State to another with the relevant VAT conditions satisfied. A Bulgarian consultancy supplying an eligible business customer in Germany may therefore have VIES reporting even though no goods move.
The NRA’s VIES guidance should be read with Articles 44, 196 and 262–264 of Directive 2006/112/EC. Those provisions connect the place of supply, customer liability for VAT and recapitulative reporting. The result is not a rule that every service sold abroad belongs in VIES. Services subject to a special place-of-supply rule, customers outside the EU and consumer sales require separate classification. Purchases from an EU supplier also should not be copied into the Bulgarian supplier-side VIES return merely because they are cross-border.
A VIES validation checks the customer’s VAT identification against information supplied by the relevant Member State. Retain the date, result, number checked and available consultation reference with the transaction records. Check that the contracting entity and invoice recipient are the business whose number you validated. A valid number does not, by itself, prove where goods travelled, establish which establishment received a service or satisfy every condition for applying the chosen VAT treatment.
If the number is invalid, ask the customer to confirm the full identifier and its status for intra-EU trade. Distinguish an incorrect number from a technical service interruption. Keep the response and review the tax position before treating the transaction as an ordinary qualifying intra-EU supply. Repeatedly testing the same incomplete number without resolving the underlying facts does not improve the evidence.
Intrastat concerns goods, including movements that require analysis beyond a sales invoice, such as transfers of your own stock. The reporting threshold is measured separately for goods arriving in Bulgaria and goods dispatched from Bulgaria. For 2026, the NRA publishes thresholds of €899, 874 for intra-EU imports and €1, 150, 407 for intra-EU exports, under the NSI’s annual order. These are statistical reporting thresholds, not VAT-registration thresholds or exemptions from VAT.
An annual obligation can arise because the previous year’s trade exceeds the threshold applicable to the current year. A current-year obligation can arise when cumulative trade exceeds the relevant threshold during that year. Monitor both flows separately from January and reassess the next year’s thresholds when published. A company buying substantial quantities from the EU may report arrivals without reporting dispatches; selling services alone does not create goods reporting.
Provide your VAT-registration basis, customer and supplier countries, goods routes, warehouse locations and trade totals for the previous and current years. For goods, identify who owns them, where they physically move and whether the operation is a sale, return, replacement or stock transfer. For services, provide the contract, the business customer’s details and the establishment receiving the service. ARG uses those facts to define the reporting obligations before preparing declarations, so your monthly compliance reflects the actual trading model.
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.
Start with a transaction list that can be traced back to contracts, invoices and logistics records. VAT and statistical returns may legitimately differ because their scope, timing and values are not identical. The objective is an explained reconciliation, not forcing all totals to match by deleting transactions or moving them between months. Agree who supplies sales data, warehouse information and corrections, especially where different teams or external fulfilment providers hold the evidence.
Identify the reporting supplier, customer VAT number, relevant transaction type, tax period and reportable amount. Link each amount to the sales ledger and supporting invoice or adjustment. For a service, confirm why the customer-location rule applies; for goods, keep transport and receipt evidence. Where call-off stock or a triangular simplification is involved, review the specific conditions and reporting entries rather than assigning the same treatment as an ordinary sale.
A triangular transaction is more than three companies appearing on the paperwork. The parties’ VAT registrations, movement of goods, invoice chain and person liable for tax must fit the relevant simplification. Similarly, goods sent to a foreign warehouse may require review before a customer is invoiced. Send the commercial and transport sequence, not only the final invoice. This allows the reporting decision to follow the legal transaction rather than the label selected in the accounting software.
An Intrastat record needs logistics and classification information that many invoices do not contain. Depending on the flow and reporting requirements, this includes the commodity code, partner country, country of origin, nature of transaction, net mass, supplementary quantity and value, together with the relevant partner VAT identifier. The country of origin is not automatically the supplier’s country. A product bought from a German distributor may have been manufactured elsewhere, while the goods may physically enter Bulgaria from a third warehouse location.
Use the current Combined Nomenclature and reliable product descriptions. The commodity code should follow the goods’ characteristics, composition and use where the classification requires them. Do not invent a weight because a platform export leaves that field blank. Obtain specifications, packing lists or warehouse data and preserve the basis for quantities. The NRA’s Intrastat instructions also explain validation issues involving partner identifiers and the relationship between net weight and supplementary units.
There are separate, higher thresholds for reporting statistical value. For 2026 the NRA lists €9, 591, 836 for intra-EU imports and €17, 772, 506 for intra-EU exports. Crossing the ordinary reporting threshold and crossing the statistical-value threshold are different events. Review the additional required fields when your trade grows, instead of assuming that the original file structure remains sufficient throughout the year.
The ordinary Bulgarian VIES deadline is the 14th day of the month following the tax period, as explained in the NRA’s filing service. Intrastat monthly declarations are ordinarily due by the 14th of the following month. Where an Intrastat obligation first arises during the year, the first reference period has a deadline of the 20th of the following month; subsequent periods return to the normal timetable. An internal collection deadline must leave time to resolve missing details before the statutory date.
Set up the necessary qualified electronic signature and authorised access before the first submission. After filing, retain the receipt and processing result. A file transmitted to the portal may still be rejected or require correction. Check that the accepted declaration covers the intended taxpayer, period and trade flow. Where no reportable activity occurs, assess the continuing obligation under each regime; do not assume that the absence of invoices automatically ends an existing Intrastat obligation.
A physical return of goods, a reduction in the price of goods already received and a general annual turnover bonus are different events. Identify the original shipment, date of the new event, credit note and actual goods movement. The NRA’s Intrastat guidance distinguishes a return in the opposite flow from a correction of the earlier flow in the circumstances it describes. The answer also depends on whether the business has an obligation for that opposite flow or crosses its threshold because of the return.
For a price adjustment linked to identified goods already reported, the earlier Intrastat period may need correction. A general annual discount that cannot be allocated to individual goods and periods is treated differently under the published instructions. For VIES, review the VAT adjustment and the period in which it belongs. Copying one credit note into every return with the same minus sign can produce incompatible results.
Distinguish an error in previously reported data from genuinely new circumstances. Article 12 of Bulgaria’s intra-EU goods statistics legislation contains separate correction rules, including a seven-day period for reporting new circumstances. Keep the original declaration, reason for change, corrected data and acceptance result together. If the portal rejects a technically correct partner identifier or quantity relationship, gather the evidence and follow the NRA’s clarification procedure instead of changing accurate commercial data just to pass validation.
Using the Union OSS scheme for eligible consumer sales does not remove Intrastat obligations for goods physically crossing Bulgaria’s border. Reconcile marketplace and OSS information with the relevant goods flows when measuring the statistical thresholds. Equally, goods sold by a Bulgarian company from a warehouse abroad require analysis of the actual route; company incorporation in Bulgaria does not make every foreign shipment a Bulgarian arrival or dispatch.
Northern Ireland has specific treatment for goods. The NRA explains the use of the XI identifier for relevant goods trade, while a GB identifier is not validated in VIES for ordinary intra-EU trade after Brexit. Do not extend the Northern Ireland goods treatment to all UK services. Record the destination, transaction type and identifier together so the correct regime is selected.
To start, send ARG representative invoices, VAT details, a description of your goods and service flows, warehouse locations, previous returns and cumulative trade totals. We can then identify the first reporting period, missing product data and the people responsible for supplying it. The monthly result should include declarations supported by the records, acceptance evidence and a clear list of corrections or unresolved differences requiring action.
Compare the related procedures in this category, including their requirements and the stage at which you need them.
.svg)
.svg)
