When a company (EOOD, OOD, AD) is in the process of liquidation, it has the right to choose whether to retain its VAT registration until its final deletion from the Commercial Register, or to proceed with VAT deregistration. This decision is important and carries financial and administrative consequences.

Application for Deregistration

Upon cessation of activity and the commencement of liquidation procedures, the company's liquidator must file an application for VAT deregistration with the competent territorial directorate of the НАП. The time limit for filing the application is 14 days, running from the date of entry of the liquidation in the Commercial Register.

  • If the company chooses to remain registered for VAT until its final deletion: The liquidator may submit a free-text declaration to the НАП within this 14-day period in order to retain the registration. In this case, the liquidator bears joint and several liability for all tax obligations arising during the liquidation.
In Which Cases Is Retaining VAT Registration Appropriate?

If the company will continue to carry out economic activity during the liquidation period, retaining VAT registration has its benefits. Terminating VAT registration before all activities are completed may give rise to the need for re-registration if the company continues with activities that meet the criteria for VAT registration. Under the Value Added Tax Act (ЗДДС), upon deregistration the company is deemed to make a supply of all available assets in respect of which a tax credit has been used. For this reason, the company will owe VAT on all available assets as at the date of deregistration.

Procedure and Documents Required for VAT Deregistration

The application for VAT deregistration must be filed using a template (Annex No. 8 to the Regulations for the Application of the ЗДДС – ППЗДДС). The application must state the legal basis for deregistration.

  • Required statements and documents: Various statements must be enclosed with the application, depending on the specifics of the company's activity and its turnover. Some of them are as follows:
    • A summary statement of the taxable turnover by month for the last 12 months.
    • A statement of intra-Community acquisitions (ВАП) for the preceding and current year (in certain cases).
    • A statement of the tax bases of distance sales within the country.
    • VAT registration certificates (Article 104, paragraphs 1 and 2 of the ЗДДС).

    In addition, together with the VAT return for the last tax period, a protocol-inventory under Article 111 of the ЗДДС (Annex No. 9 to the ППЗДДС) must also be filed, which is included in the sales ledger for the last tax period.

Verification and Decision on Deregistration

Within a 7-day period after the deregistration application is filed, the revenue authority carries out a verification to establish whether the conditions for deregistration are met. After the verification is completed, the НАП has a further 7 calendar days to issue an act of deregistration or to refuse to carry it out with reasons.

  • Date of deregistration: If deregistration is approved, the date of deregistration is deemed to be the date of entry of the liquidation in the Commercial Register.
Key Points of VAT Deregistration upon Liquidation

  1. Financial obligations upon deregistration: Upon deregistration, the company may be required to charge and pay VAT on all assets in respect of which it has used a tax credit, as at the date of deregistration.

  2. Liability of the liquidator: The liquidator is responsible for the proper fulfilment of the VAT obligations, including the declarations filed and the tax due during the liquidation period.

  3. Option to retain registration: If the company will continue economic activity, it may choose to retain its VAT registration, but it must declare this intention within 14 days of the date of entry of the liquidation in the Commercial Register.

VAT deregistration upon liquidation requires careful planning in order to avoid additional tax costs and liabilities.

Should you require additional information, assistance or a consultation in connection with the liquidation of an EOOD, OOD or AD, contact us by telephone: 0887550706 or by e-mail: