VAT on Facebook and Google Ads in Bulgaria — Art. 97a VAT Act registration

In brief: If your company is not VAT-registered and pays Meta Platforms Ireland or Google Ireland for ads, you will usually need to register under Art. 97a of the VAT Act at least 7 days before the tax becomes chargeable, and self-assess 20% VAT on the ads. This registration gives no right to input VAT credit — the VAT is a real cost.

Why the obligation arises

Advertising is a business-to-business service. When the customer is a taxable person, the place of supply is where the customer is established (Art. 21(2) VAT Act) — in this case Bulgaria. The supplier (Meta or Google, established in Ireland) does not charge Bulgarian VAT. Instead, the customer owes the tax under the reverse charge (Art. 82(2) VAT Act).

To account for this VAT, an unregistered company needs a VAT number. That is why Art. 97a(1) of the VAT Act requires anyone receiving services with a place of supply in Bulgaria from a supplier established in another EU country to register. The application must be filed no later than 7 days before the date on which the tax on the service becomes chargeable.

Who is affected

Situation	Is Art. 97a registration required?
EOOD without VAT registration paying Meta Platforms Ireland for Facebook/Instagram ads	Yes
EOOD without VAT registration paying Google Ireland for Google Ads	Yes
Freelancer without VAT registration buying a software subscription from an EU supplier	Yes, if they are a taxable person
Company already VAT-registered (Art. 96 or Art. 100)	No — it self-assesses VAT under its existing registration
Private individual with no business activity	No — the platform charges VAT as to a consumer

Art. 97a registration also applies the other way round — when an unregistered Bulgarian company sells services to businesses in the EU (Art. 97a(2)).

How it works in practice

File an Art. 97a registration application with the NRA before your first ad payment.
Enter your VAT number (BG…) in your ad account. The platform stops charging Irish VAT and issues invoices without VAT, marked as reverse charge.
For each invoice, prepare a protocol under Art. 117 of the VAT Act and charge 20% VAT.
File a monthly VAT return by the 14th of the following month and pay the tax.

No input VAT credit: a business registered only under Art. 97a cannot deduct the VAT it charges. If you spend €1,000 a month on ads, you pay €200 VAT to the NRA, and it stays a cost. If the company is registered under the standard rules (Art. 96 or Art. 100), the same €200 is charged and deducted at the same time — the net effect is zero.

What happens if you do not register

If you do not enter a VAT number, the platform may treat you as a consumer and charge Irish VAT, which you cannot recover. At the same time, Bulgarian VAT is still due, and the VAT Act provides for financial penalties for failing to apply for registration. The NRA receives data on payments to foreign platforms and advertisers, so gaps are found.

When standard VAT registration is the better option

If you spend a lot on ads and sell mainly to businesses, voluntary registration under Art. 100 of the VAT Act may be cheaper: you deduct the VAT on your ads, and your VAT-registered business customers deduct the VAT you charge them. If you sell to consumers, work out the effect on your prices. Compare: VAT registration — when it is mandatory and how it works and the VAT threshold for 2027.

Deregistration

Art. 97a registration ends when the reason for it no longer applies — for example, you stop advertising and receive no other services from the EU. It is not automatic: you must file a deregistration application with the NRA.

Paying for ads without VAT registration?

We register you under Art. 97a, prepare the protocols and file your returns every month — or show you when standard registration makes more sense.

Get in touch

Frequently asked questions

Do I need to register for VAT if I pay for Facebook ads?

If your company is not VAT-registered and pays Meta Platforms Ireland for ads — yes, as a rule you need to register under Art. 97a of the VAT Act and self-assess 20% VAT.

Can I deduct the VAT if I am registered under Art. 97a?

No. A business registered only under Art. 97a charges and pays VAT but has no right to input VAT credit.

When do I file the Art. 97a application?

No later than 7 days before the date on which the tax on the service becomes chargeable. In practice, before your first ad payment.

What is a protocol under Art. 117 of the VAT Act?

The document the customer uses to charge VAT under the reverse charge. You prepare one for each invoice from an EU supplier.

Sources

VAT Act — lex.bg

This article is general information, not legal advice. Current as of 2 November 2026.

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VAT on Facebook and Google Ads — do you need to register under Art. 97a?