On 20 June 2018, on a taxpayer's request, the National Revenue Agency (NRA) issued a letter concerning the application of self-invoicing rules when the supplier and the recipient are established in two different EU Member States.
(a) Facts. A Bulgarian company involved in freight road transport concluded an agreement for self-invoicing with its client from another EU Member State. The Bulgarian company received invoices issued on its behalf with numbers that differed from its own numbering.
(b) Question. The company raised a question whether, in the case of self-invoicing when a foreign client is issuing the invoices, the Bulgarian company must issue and report duplicates of the invoices that have already been issued on its behalf by the client.
(c) Comments. The National Revenue Agency confirmed that, based on article 79b of the Regulations for Application of the VAT Act (RAVATA), self-invoicing is also possible in cases when the supplier and the recipient are established in two different EU countries. Furthermore, according to article 79b(5) of the RAVATA, when the service has a place of supply in another EU Member State, and the recipient is also established in another EU Member State, the supply should be documented according to the rules of the country where the place of supply is.
The NRA therefore determined that the documents issued by the foreign client should be valid for Bulgarian VAT purposes and should be reported in the sales ledger and in the VAT and VIES returns of the Bulgarian supplier. The NRA also noted that the Bulgarian VAT legislation does not envisage a possibility for issuing invoices by the supplier in the case of a self-invoicing arrangement.