Bulgaria / Poland · International tax development
Bulgaria publishes VAT cooperation agreement with Poland
On 20 October 2026, Bulgaria published an agreement between its National Revenue Agency and Poland's National Revenue Administration for faster and recurring VAT-information exchanges concerning cross-border transactions and company ownership.
- Official document:
- VAT cooperation agreement of 2 October 2026, Bulgarian State Gazette No. 96
- Development date:
- 2026-10-20
The agreement builds on EU administrative-cooperation rules
The bilateral agreement was approved by Bulgaria's Council of Ministers in October 2024, signed on 2 October 2026 and entered into force on signature. It operates within Council Regulation (EU) 904/2010 on VAT administrative cooperation and fraud prevention. It does not change VAT rates, taxable amounts or taxpayer filing obligations; it creates direct channels between designated Bulgarian and Polish liaison offices and officials, alongside exchanges through the central liaison offices.[1][2]
Case information has a ten-working-day target
For request-based and spontaneous exchanges concerning particular cases, Article 3 permits information on whether taxpayers involved in intra-EU transactions exist, persons participating in the capital, management or control of companies in the other state, and the VAT base and amount for transactions between taxpayers in the two states. The administrations undertake to use their best efforts to supply requested case information within ten working days. Either administration may exclude entities considered strategic to its economy or defence, provided it informs the other administration of the excluded list.[1]
Recurring exchanges cover transactions and ownership
The authorities also agree to exchange information spontaneously about intra-EU acquisitions of goods and received services between operators in the two countries, generally by the end of the month following the month in which the taxpayer's domestic reporting obligation arises. Corrections follow on a quarterly cycle. Information about cross-border participation in company capital, management or control is also to be exchanged quarterly. A joint coordination group will set the transaction-value threshold, exact data scope, format and secure electronic means, and will review implementation annually.[1]
Operational use awaits technical notifications
Although the agreement is in force, Article 9 separates entry into force from application: the exchange arrangements apply only from the date on which both administrations notify each other that the necessary technical and organisational measures are complete. The Gazette text does not state that notification date. Groups trading between Bulgaria and Poland should therefore expect more coordinated VAT risk analysis and ownership checks, but should not assume the recurring exchanges are already operational or treat the agreement as creating a new return. Existing record-keeping and VAT positions will supply the data against which the two administrations can compare cross-border activity once implementation begins.[1]
Official sources
- [1] Agreement between the Bulgarian National Revenue Agency and the Head of the Polish National Revenue Administration on enhanced VAT cooperation
Bulgarian State Gazette · Document date: 2026-10-20
State Gazette No. 96, page 42, complete Articles 1–11 read. Opening recital records approval, signature and entry into force; Article 2 designates liaison offices; Article 3 defines request, spontaneous and recurring exchanges and the ten-working-day target; Articles 4 and 7 reserve threshold and technical details to the joint group; Article 9 delays application until mutual completion notifications.
- [2] Council Regulation (EU) No 904/2010 on administrative cooperation and combating fraud in the field of VAT
Official Journal of the European Union · Document date: 2010-10-12
Current official instrument identified as the legal framework expressly invoked by the bilateral agreement; relevant provisions are Articles 4, 7, 13, 15, 28–30 and 55.