The overriding motivation for countries to introduce e-reporting and e-invoicing mandates is typically to realise a reduction of the VAT gap, which is defined as the projected VAT revenue collected by governments, compared to the actual VAT revenue accumulated. These processes allow for greater visibility of tax activity, which in principle serves as the basis for increased compliance with VAT obligations.

One way to enforce this increased scrutiny on tax activity is by shining a lens on high fiscal risk products, which can be defined as goods which are the most susceptible to fall short of VAT compliance obligations. Most notably, in 2022, we saw a similar process initiated in Romania.

To this effect, the Bulgarian National Tax Authority (NRA) is obligating the preliminary declaration of data concerning the transportation of high fiscal risk goods, via Ordinance NoH-5.

Order ZMF – 1295/28.12.2023 categorises the new products that fall under the category of high fiscal risk products.

To implement the provisions of the Ordinance, Bulgaria will follow a two-tiered execution concerning its enactment, focusing on the following areas:

• October 2023: intra community transactions from / into Bulgaria
• January 2024: movement of goods between two different destinations in Bulgaria, and cross-border transactions.

In terms of the functionality of the process, data relating to these transactions must be declared through an E-Services Portal, which is accessible via a qualified signature. In turn, the NRA system will generate a unique transportation number, which must be passed to the entity transferring the goods.

While Bulgaria is a compliant territory for Kofax, Kofax will not be supporting the declaration of high fiscal risk products data to the E-Services Portal; however, we can continue to assist suppliers and buyers with our standard e-invoicing solution in the country, where we create the legal invoice on behalf of suppliers and deliver this to our buyers.