Online sales through e-commerce stores from Bulgaria to EU countries

There is such a concept as the free movement of goods within the EU – without additional costs or quantity restrictions. However, this does not apply to all goods. For example, when selling fertilisers or excise goods, other rules must be observed. In addition, companies selling goods abroad must comply with certain requirements regarding VAT.

There are quite a few nuances concerning online trade with EU countries. For example, if a product is not sold within three months, the company must have a warehouse – the rental agreement must be submitted to the National Revenue Agency (NAP). At the same time, if the goods go directly from the supplier to the buyer, there is no need to rent warehouse space.

EU rules

• Before entering the EU market with your products, you need to make sure that the goods meet European Union requirements in terms of protecting human and animal health, protecting the environment and consumer rights.
• Although sellers may limit delivery options, all customers in the European Union must have equal access to the goods. This also applies to special prices, discounts and terms of sale – they must be the same for buyers in Bulgaria and outside it, in other European Union states, regardless of the buyers’ nationality and location.
• The rules apply to both offline and online transactions with end consumers (i.e. persons who do not plan to resell, exchange, rent out or process the purchased goods).
• Customers must be able to access all versions of the website as they wish. For example, if a buyer in Italy wants to use the Spanish version, they must not be automatically redirected to the Italian one. Redirection takes place only at the customer’s request and with their consent, and the buyer may change their mind and their decision at any time.
• If the store offers on-site collection of goods, customers from other European Union countries to which delivery is not offered must be given the opportunity to arrange delivery themselves or collect the goods.

Reports and declarations on the movement of goods

When carrying out exports and/or imports within the EU, a statistical report on the movement of goods must be submitted to Intrastat. Declarations containing all the necessary data are filed with NAP (the tax authority).

This obligation arises once a certain threshold is reached, which is set annually. There are separate thresholds for import and export transactions, set by the National Statistical Institute, and they may differ. The threshold values for the following year are published annually in October.

Thus, in 2020, exports had to be declared in the Intrastat system starting from an amount of 290000 leva and imports starting from an amount of 470000 leva. In addition, statistical value thresholds were set: exports – 15800000 leva, imports – 7600000 leva. The threshold for simplified declaration of individual low-value transactions under the Intrastat system in 2020 is 390 leva.

If the total amount of transactions has reached or exceeded the specified threshold, the company is obliged to submit reports monthly. As long as turnover is below the established threshold, there is no need to declare, but from the moment the amount exceeds the threshold, a report must be submitted to Intrastat monthly until the end of the year. Moreover, the obligation to submit reports until the end of the year remains even if turnover decreases and the reports for some months are nil.

If the company’s exports/imports in the previous year exceed the specified threshold, the report must be submitted starting from January. Example: the EU country with which transactions are carried out set the import threshold in 2019 at 100 thousand euros. If in 2018 the company’s imports exceeded the amount of 100 thousand euros, then reports must be submitted starting from January 2019.

If in the previous year exports/imports did not exceed the threshold, but this happened in the current year, you must start submitting reports beginning with the month in which the threshold was exceeded. Example: the EU country with which transactions are carried out set the import threshold for 2018 at 100 thousand euros. From January to June 2018 the total amount of imports was 90 thousand euros. The threshold was exceeded in July 2018, when the company imported goods worth 15 thousand euros, and starting from that month the statistical report must be submitted. In such a situation, the first Intrastat declaration will relate to imports in July 2018 amounting to 15 thousand euros.

Important: it may be necessary to submit a report on the movement of goods from/to EU states in which the company does not have a representative office.

If the company carries out transactions with other European Union countries but the annual turnover is less than the established threshold, summary information must be submitted together with the VAT returns.

Submission of reports on the movement of goods

Businesses and individuals registered for VAT that dispatch or receive goods must submit reports when the amount of exports or imports exceeds a certain annual threshold.

Reports must be submitted at least once a month for transactions in the previous month. The deadline for sending the data is determined by the relevant authorities in each European Union country.

At the same time, only the physical movement of goods from one EU country to another must be reported. If it is only a matter of cross-border services that do not involve the movement of goods between states, then there is no need to submit reports to the Interstat system.

A standard report must include the following information:

• VAT identifier.
• The period covered by the report.
• The direction of the flow – export or import.
• The 8-digit numerical product code in accordance with the Combined Nomenclature (CN).
• The code of the EU country to which the goods are dispatched/from which they are supplied.
• The value of the goods excluding VAT and excise duties. If the value is related to processing, you need to obtain the value of the processed goods and then calculate the value of the raw materials plus all additional costs associated with the processing.
• The net quantity of goods.
• Units of measurement according to the CN (litre, item, sq. metre, etc.)
• The transaction nature code (indicating purchase, sale or processing).

In some cases, additional information may be required, for example about the type of transport used for carriage.

In 2020, the National Statistical Institute (NSI) requirements for reports stipulate that the document must contain the following data:

• Product code.
• The EU country with which the transactions are carried out.
• Country of origin (when receiving goods).
• Type of transaction.
• Delivery terms.
• Mode of transport.
• The country in which the vehicle is registered.
• Region of origin/consumption.
• Net weight in kilograms.
• Quantity.
• Value.
• Statistical value.

Preparing all the reporting on your own can be difficult, so it is advisable to turn to specialised companies to handle the paperwork. The staff of Bulgarian Expert will be glad to help you prepare your reporting.

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