The analysis does not start with the passport
Two nationals of the same country can have very different VAT positions. The first questions are where the person lives and carries on the activity, what is supplied, to whom, and where the place of supply is.
The question “I am a foreign national — do I need VAT registration?” therefore almost always requires additional facts.
A person living and working from Bulgaria
Where an individual has a permanent address or habitual residence in Bulgaria and carries on an independent economic activity, the general rules for persons established in Bulgaria may apply.
From 2026, the general obligation arises when annual turnover in Bulgaria exceeds EUR 51,130. Foreign nationality does not displace the Bulgarian VAT rules.
A person established in another EU Member State
The Bulgarian transactions, any fixed establishment, and possible use of the EU SME scheme must then be considered.
The cross-border SME scheme is not an automatic exemption. Its conditions include total annual EU turnover of no more than EUR 100,000 and compliance with the national threshold in the Member State granting the exemption.
A person established outside the European Union
For taxable supplies with a place of supply in Bulgaria, special rules may require registration before the first supply without waiting for the general national threshold.
The result depends on the type and place of supply and on who is liable for the tax.
No company does not mean no VAT
VAT applies to taxable persons carrying on an independent economic activity, not only to incorporated companies.
A consultant, independent professional, or other individual can carry on an economic activity without a Bulgarian limited company.
Example: an IT consultant
A foreign individual lives in Bulgaria and regularly provides IT consulting services. Before reaching a VAT conclusion, we ask:
- Where does the person habitually live and work?
- Are the customers businesses or private individuals?
- Are they in Bulgaria, the EU, or outside the EU?
- What turnover is generated and by which supplies?
- Are services received from foreign suppliers?
- Does the person have another EU VAT registration or use an SME scheme?
The bank account does not determine the treatment
Receiving money through Revolut, Wise, or a foreign bank account records a movement of funds but does not answer the VAT question.
The analysis follows the economic activity and the supplies: who supplies what, to whom, and where.