EU VAT Registration for Small Businesses: Bulgaria, Hungary & All 27 Countries Compared
If you are running a small business or freelancing across Europe, VAT registration is one of those things that feels more confusing than it actually is. This guide walks you through how VAT registration works in the EU, what the thresholds are in each country, and takes a closer look at Bulgaria and Hungary — two countries where the rules catch a lot of new business owners off guard.
Part 1: What VAT Registration Actually Means
Let us start with the basics, because a lot of people confuse VAT registration with tax residency or business licensing. They are three different things.
When you register for VAT, you get a unique VAT identification number (sometimes called a VAT ID, VAT number, or VAT registration number). This number proves you are registered to charge and reclaim Value Added Tax. It is separate from your company registration number, your tax file number, and your trade licence.
Once you have a VAT number, you have two obligations:
- Charge VAT on your sales: You add VAT to your invoices at the applicable rate for your country. Customers who are VAT-registered can usually reclaim this VAT as input tax.
- Report and pay VAT to the tax authority: You file periodic VAT returns (usually monthly or quarterly) showing how much VAT you collected on sales minus how much you paid on purchases. The difference is what you owe the tax authority — or what they owe you if you paid more input VAT than you collected.
The reason VAT exists in this "credit and debit" structure is to avoid cascading taxes — where tax is charged on tax at every stage of the supply chain. Under VAT, each business in the chain only pays tax on the value it adds, not on the total price of goods passing through its hands.
When Must You Register?
Every EU country sets a VAT registration threshold — a turnover level above which VAT registration becomes mandatory. Below that threshold, you generally do not need to charge VAT. Once your turnover crosses it, you must register within a specified number of days (usually 14 to 30 days).
There are also situations where you must register regardless of turnover:
- Cross-border B2B services: If you provide services to VAT-registered businesses in other EU countries, you may need to register (or use the reverse charge mechanism)
- Distance sales: If you sell goods online to consumers in other EU countries above the €10,000 OSS threshold, you must charge the customer's country VAT and register there (or use the One Stop Shop)
- Import/export: If you import goods from outside the EU, you need a VAT number to clear customs
- Storage in another country: If you store inventory in a different EU country (common for Amazon FBA sellers), you must register in that country
Part 2: VAT Registration Thresholds Across the EU (2026)
The threshold is the number that matters most when you are starting out. Here is where every EU country stands in 2026:
| Country | Threshold (approx. EUR) | Standard VAT Rate |
|---|---|---|
| Hungary | €30,000 | 27% |
| Netherlands | €30,000 | 21% |
| Cyprus | €15,600 | 19% |
| Slovakia | €50,000 | 23% |
| Bulgaria | €51,130 | 20% |
| Croatia | €60,000 | 25% |
| Germany | €25,000 | 19% |
| France | €37,500 (services) / €85,800 (goods) | 20% |
| Italy | €85,000 (services) / €65,000 (goods) | 22% |
| Spain | €40,000 | 21% |
| Poland | PLN 240,000 | 23% |
| Belgium | €35,000 | 21% |
| Austria | €55,000 | 20% |
| Ireland | €42,500 (services) / €85,000 (goods) | 23% |
| Sweden | SEK 120,000 | 25% |
| Denmark | €41,700 | 25% |
| Finland | €20,000 | 25.5% |
| Portugal | €14,500 (services) / €12,500 (goods) | 23% |
| Greece | €10,000 | 24% |
| Czech Republic | €80,000 | 21% |
| Romania | RON 395,000 | 21% |
| Latvia | €45,000 | 21% |
| Lithuania | €45,000 | 21% |
| Estonia | €40,000 | 24% |
| Slovenia | €50,000 | 22% |
| Luxembourg | €35,000 | 17% |
| Malta | €37,000 | 18% |
Last verified: 25 September 2026. Sources: EU Commission VAT rates, ECB euro reference rates and national tax authorities. Confirm with your local authority before filing.
Notice how wide the range is — from €10,000 in Greece to €85,800 for goods in France. This means a freelance graphic designer earning €50,000 might need to register for VAT in Hungary, Bulgaria, Germany, and the Netherlands, but not in France, Italy, or Belgium.
For a complete breakdown of every rate including reduced rates, check the EU VAT Rates 2026 reference.
Part 3: Bulgaria VAT — The Complete Picture
Bulgaria has become popular with digital entrepreneurs and outsourcing companies, partly because of its low corporate tax rate (10%) and relatively straightforward VAT registration process. But there is a catch that catches many people out: the threshold is low.
Bulgaria VAT at a Glance
How to Get a Bulgarian VAT Number (BGN VAT ID)
The Bulgarian VAT number starts with the prefix BG followed by 9-10 digits. Here is the process:
- Prepare your documents: Certificate of incorporation, articles of association, tax registration certificate, proof of business activity (contracts, invoices), and passport/ID of the director.
- Submit to the National Revenue Agency (NRA): You can apply online through the NRA portal or submit a paper application (Form No. 3). Online submission is faster.
- Wait for processing: Typically takes 1-2 weeks for EU-established businesses. Non-EU businesses need a fiscal representative, which can extend this to 2-3 weeks.
- Receive your VAT number: You will get a BG-prefixed VAT ID that is valid across the EU and can be verified through VIES.
Who Needs to Register in Bulgaria?
- Businesses with annual taxable turnover exceeding BGN 100,000 in Bulgaria
- Businesses providing services to Bulgarian VAT-registered customers (reverse charge may apply, but registration is often needed)
- Non-EU businesses selling goods to Bulgarian consumers above the €10,000 OSS threshold
- Businesses storing goods in Bulgarian warehouses (common for Amazon FBA sellers using Bulgarian fulfilment centres)
Bulgaria VAT Return Filing
Bulgarian VAT returns must be filed monthly, by the 14th day of the month following the reporting period. If the 14th falls on a weekend or holiday, the deadline extends to the next working day. Annual VAT returns are also required, filed by February 28 of the following year.
The VAT return must be filed electronically — paper submissions are no longer accepted. Late filing penalties start at BGN 500 for the first offence and escalate for repeat violations.
If you need to calculate VAT on Bulgarian invoices, use the free VAT Calculator — Bulgaria's 20% standard and 9% reduced rates are built in.
Part 4: Hungary VAT — What You Need to Know
Hungary has the highest standard VAT rate in the EU at 27% and one of the lowest registration thresholds at approximately €30,000. If you are doing business in Hungary, these two facts will shape almost every financial decision you make.
Hungary VAT at a Glance
Hungarian VAT Number Format
Your Hungarian VAT ID starts with HU followed by 8 digits. For example: HU12345678. You can verify any Hungarian VAT number through the VIES VAT Validator to confirm it is active and valid.
How to Register for Hungarian VAT
- Gather documents: Company registration certificate, articles of association, tax identification number, director's passport, proof of business activity (minimum 2-3 sample invoices or contracts), and a power of attorney if using a fiscal representative.
- Submit application to NAV (National Tax and Customs Authority): The application is Form 2201 for domestic businesses or Form 2202 for foreign businesses. Submission can be done electronically via the NAV portal.
- Appoint a fiscal representative (non-EU businesses only): If your business is established outside the EU, you must appoint a Hungarian fiscal representative who is jointly liable for your VAT obligations.
- Wait for processing: Typically 2-4 weeks. NAV may request additional documentation, which can extend the timeline.
- Receive your HU VAT number: Once approved, you receive your HU-prefixed VAT ID. The number becomes active in VIES within 1-2 days.
Hungarian VAT Return and Reporting
Hungary requires monthly VAT returns, filed by the 20th of the month following the reporting period. In addition to the standard VAT return, Hungary requires two supplementary returns annually (in July and January covering the previous half-year).
Hungary also operates an e-invoicing mandate — invoices between VAT-registered businesses must be issued through the government's online invoice reporting system (Online Számla). This is separate from the ViDA e-invoicing requirements and has been mandatory since 2018 for B2B transactions.
If you are issuing invoices to Hungarian customers, make sure your invoices include the required elements and are reported through Online Számla. The free Invoice Generator creates compliant invoices with all required fields.
The 27% Rate: Why It Matters for Pricing
Hungary's 27% standard VAT rate directly affects your pricing strategy. Consider this example:
If you are selling to Hungarian consumers, your prices are effectively 8-10% higher than equivalent offers from German or Luxembourg competitors — purely because of the VAT rate. This matters for price-sensitive markets.
However, for B2B sales where the customer reclaims input VAT, the rate does not matter as much — the 27% is neutralised in the customer's VAT return.
Part 5: Small Business VAT Schemes Across the EU
Most EU countries offer some form of small business exemption that lets you avoid charging VAT below a certain turnover level. These schemes have different names in each country, but they all work on the same principle: if your turnover is below the threshold, you do not charge VAT and cannot reclaim input VAT.
| Country | Scheme Name | Threshold | Key Condition |
|---|---|---|---|
| Germany | Kleinunternehmerregelung | €25,000/yr | Cannot charge VAT or reclaim input VAT |
| France | Franchise en base | €91,900 (services) / €85,800 (goods) | Must state "TVA non applicable, art. 293 B du CGI" on invoices |
| UK | VAT Registration Exemption | £90,000 | Voluntary registration allowed above £1,000 |
| Austria | Kleinunternehmerregelung | €55,000/yr | Similar to German scheme |
| Netherlands | Kleine ondernemersregeling | €30,000/yr | Can opt to pay 0% VAT while still registered |
| Hungary | Small business exemption | €30,000/yr | Must notify NAV within 30 days of exceeding threshold |
| Bulgaria | Small business exemption | €51,130/yr | Must register within 14 days of exceeding threshold |
Should You Use the Small Business Scheme?
The answer depends entirely on who your customers are:
- If you sell B2B (to other VAT-registered businesses): You are usually better off registering for VAT even below the threshold. Your customers cannot reclaim VAT you charge, so it becomes a cost to them — making your prices less competitive than VAT-registered competitors. Voluntary registration lets you issue proper VAT invoices and lets customers reclaim the VAT.
- If you sell B2C (to consumers): The small business scheme can make you more price-competitive, because consumers cannot reclaim VAT anyway. Your prices are lower than VAT-registered competitors.
- If your input VAT costs are high: Registering for VAT lets you reclaim input VAT on your purchases. If you spend €50,000 per year on VAT-taxable inputs at 20% VAT, that is €10,000 you could reclaim — far more than any benefit from the threshold exemption.
For country-specific registration processes, see our detailed guides:
Part 6: Cross-Border Selling and the OSS
If you sell to customers in more than one EU country, the One Stop Shop (OSS) simplifies your VAT obligations enormously. Before OSS, you had to register for VAT in every country where you exceeded the distance selling threshold — a bureaucratic nightmare.
How the OSS Works
- Register for OSS in your home country (one single registration)
- Charge the customer's country VAT on B2C sales to other EU countries — if a French consumer buys from you, you charge French VAT (20%), not your home country rate
- File one quarterly OSS return covering all EU cross-border B2C sales — instead of separate returns in every country
- Pay all the VAT in one payment with your OSS return
The €10,000 OSS Threshold
The €10,000 combined threshold applies across all EU countries, not per country. If your total cross-border B2C distance sales to other EU member states exceed €10,000 in a calendar year, you must charge the destination country's VAT rate.
Below €10,000, you can charge your home country VAT rate on all cross-border sales — a significant simplification for very small businesses.
When You Still Need Local Registration
The OSS covers B2C distance sales, but you may still need local VAT registration in another EU country when:
- You store goods in another country (Amazon FBA warehouses are the most common trigger)
- You make B2B sales that require local registration (some countries require this for certain services)
- You host live events or conferences in another country
- You provide admission to events or cultural services physically in another member state
The free Reverse Charge OSS Checker helps you determine which regime applies to your specific sales situation.
Your VAT Registration Action Checklist
- Determine your threshold: Check the VAT registration threshold for your country — if you are near it, prepare to register before you cross it.
- Decide whether to register voluntarily: If most of your customers are businesses, register even below the threshold.
- Gather your documents: Certificate of incorporation, articles of association, director's ID, proof of business activity (invoices, contracts).
- Submit your application: Most countries allow online submission through their tax authority's portal.
- Verify your VAT number: Once you receive it, check it on VIES to confirm it is active.
- Update your invoices: Add your VAT number, VAT rate, VAT amount, and all other required fields. Use the Invoice Generator for compliance.
- Set up VAT return reminders: Missed filings result in penalties. Most countries require monthly or quarterly returns.
- Calculate VAT correctly: Use the VAT Calculator for any country's rates — standard, reduced, and super-reduced.
- Review cross-border obligations: If you sell to other EU countries, check whether OSS or local registration applies.
- Keep records: VAT records must be retained for at least 7 years in most EU countries (10 years in some).
Frequently Asked Questions
What is the VAT registration threshold in Bulgaria?
Bulgaria has one of the lowest VAT registration thresholds in the EU at BGN 100,000 (approximately EUR 51,139) of annual taxable turnover. Once your turnover exceeds this amount, you must register for VAT within 14 days. The Bulgarian VAT rate is 20% standard and 9% reduced.
What is the VAT registration threshold in Hungary?
Hungary's VAT registration threshold is HUF 12 million (approximately EUR 30,000) of annual taxable turnover, making it one of the lowest in the EU. The Hungarian VAT rate is 27% standard — the highest in the EU — with reduced rates of 18% and 5%.
Do I need a VAT number to sell to other EU businesses?
Yes. If you sell goods or services to VAT-registered businesses in other EU member states, you need a valid VAT number. B2B cross-border transactions within the EU are typically reverse-charged, meaning the customer accounts for the VAT — but both parties need valid VAT numbers for this to apply.
How long does VAT registration take in the EU?
VAT registration timelines vary by country: Germany takes 4-8 weeks, France 2-6 weeks, Bulgaria 1-2 weeks, Hungary 2-4 weeks, and Ireland 2-4 weeks. Some countries require a fiscal representative for non-EU businesses, which can add 1-2 weeks. Digital submission is available in most countries.
What is the lowest VAT threshold in the EU?
Several EU countries have very low VAT thresholds: Hungary at EUR 30,000, Cyprus at EUR 15,600, Slovakia at EUR 50,000, and Bulgaria at EUR 51,130. The highest thresholds are in Ireland (EUR 85,000 for goods, EUR 42,500 for services) and France (EUR 85,800 for goods). Most countries fall in the EUR 30,000 to EUR 85,000 range.
Can I register for VAT voluntarily before hitting the threshold?
Yes, in most EU countries you can register for VAT voluntarily even if your turnover is below the threshold. This is often beneficial if you sell B2B to VAT-registered customers who want to reclaim input VAT, or if your input VAT costs are high. However, once registered, you must charge VAT on all taxable supplies and file regular VAT returns.
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Disclaimer: This article provides general information about VAT registration in EU member states. Thresholds, rates, and rules change frequently. This is not tax advice — consult a qualified tax adviser for your specific situation. Information is current as of September 2026.