Laws / Regulations

When is issuing an invoice not mandatory?

Fromadmin

We have often discussed how important it is issuing invoices and how to fulfill this obligation with minimal effort. 

Today, we will look at another aspect of invoicing: when Bulgarian legislation exempts us from this obligation.

The legal provisions we will refer to are contained in the Value Added Tax Act and materials published on the official website of the National Revenue Agency.

For supplies where the recipient is a non-taxable individual

This is the most common scenario. If you supply goods or services to an individual, issuing an invoice is not mandatory.

Naturally, the fiscal receipt is a mandatory document recording the transaction. Bulgarian legislation strictly defines the cases in which a receipt need not be issued; we will discuss these in another article.

For supplies of financial services
This refers to the financial services mentioned in Article 46 of the VAT Act— granting credit, leasing; transactions in currency, banknotes and coins; transactions in securities; transactions relating to payment systems, electronic money, debts and receivables; transactions in company interests and shares;  Given the nature of these services, it is entirely logical that they are exempt from the obligation to issue invoices.
For supplies of insurance services
Like financial services, insurance services are included in the list exempt from invoicing. This concerns insurance and reinsurance services and related services, performed by insurance brokers and agents.
For electronically supplied services by persons not established in the Community

This provision is new. It states “For supplies under the distance sales scheme for goods imported from third countries or territories, or the non-Union scheme”;

It results from recent legislative changes in e-commerce and reflects the guidelines imposed by Council Directive (EU) 2019/1995 of 21 November 2019 

What does the non-Union scheme mean? 

Under the latest amendments to Bulgarian legislation, the “Non-Union scheme” may be used by a taxable person not established in the European Union for services supplied to end customers or consumers where the place of supply is Bulgaria.

For airline ticket sales


Air passenger transport requires an individual or group travel document (ticket). Therefore, invoices are not mandatory.

For free-of-charge supplies

The additional provisions of the VAT Act define a supply free of charge as follows a supply for which no consideration is received or the value given greatly exceeds the value received. 

The different types of transactions without consideration are listed in Articles 6 and 9 of the VAT Act. Such transactions usually involve a donation agreement or a protocol. Invoicing is therefore unnecessary.

For supplies made by individuals not registered under the Act, other than sole traders


The law limits this to specific circumstances, namely where, for the supplies they make:

  • a document is issued under a special law, or
  • a statement of amounts paid or a document under Article 9 of the Personal Income Tax Act is issued, or
  • issuing a document is not mandatory under Personal Income Tax Act.

Please note that Bulgarian legislation does not require invoices to be issued in the cases listed above, but does not prohibit them either. If you would like an invoice for this type of transaction, you need to assist the other party in issuing it.

Please remember that issuing an invoice is mandatory in all other cases. I-CASH is retail and inventory software that makes the invoicing process as easy as possible.

Try it yourself by registering at https://icash.bg/bg/ and receive one month of free access to the program. 

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