Received a revision act from the NRA? The first 14 days
How to appeal a Bulgarian tax assessment: the deadline, where the appeal goes, what happens next, and why enforcement does not stop on its own.
A tax audit by the National Revenue Agency (NRA) ends with a revision act: the document that sets out any additional tax, interest and penalties the authority believes you owe. If you disagree with it, the clock starts the day it is served on you.
14 days to appeal
Under the Tax and Social Security Procedure Code, a revision act can be appealed in whole or in part within 14 days of being served. Fourteen days is not much time to review an audit file, collect documents and build arguments, so the work should start the moment the act arrives, or earlier, while the audit is still running.
Where the appeal goes
The appeal is filed through the territorial directorate of the NRA that issued the act, and is decided by the director of the competent Appeals and Tax and Social Security Practice directorate at the NRA’s central office. This administrative stage is mandatory: a revision act cannot go to court without it.
What happens next
The Appeals directorate reviews the act and your arguments and decides whether to confirm it, change it or annul it. If the decision goes against you, or if no decision is issued within the legal time limit, the act can then be challenged before the administrative court. Check the deadlines stated in the decision you receive: each step has its own.
The appeal does not stop collection
An administrative appeal does not suspend enforcement of the revision act. The NRA can begin collecting the assessed amounts while the appeal is pending. This is one of the most common surprises for companies, and the main reason the response needs planning from day one.
What makes an appeal strong
- Evidence, not only arguments. Contracts, delivery documents, correspondence and payment records that support each transaction.
- Precision. Contest the specific findings that are wrong, with reasons, rather than the act as a whole.
- Case law. Bulgarian courts have ruled on many recurring VAT issues; a well-chosen precedent carries weight.
- Consistency. What you say in the appeal must match what was said and provided during the audit.
How we can help
Our appeals are handled by tax lawyers and former tax auditors who know how audit findings are built. We review the act and the file, tell you plainly which points are worth contesting, and represent you before the NRA and the courts. Talk to us about a tax dispute.
