What DAC7 is — and why it matters for hosts
DAC7 is the seventh amendment to the EU Directive on Administrative Co-operation in the field of taxation — Directive (EU) 2021/514, adopted on 22 March 2021. It applies from 1 January 2023 across all Member States. The aim is automatic exchange of information between tax administrations on income earned through digital platforms — from Airbnb to eBay.
In Bulgaria the regime was transposed by amending the TIPC (State Gazette, issue 17 of 1 March 2022), which created Chapter Sixteen, Section VIII TIPC — “Automatic Exchange of Information Provided by Digital Platform Operators”. The implementing instrument is Ordinance H-1 of the Minister of Finance.
Why the “black box” era is over
Until 2022, a host renting through Booking or Airbnb could realistically rely on the fact that:
- The platform was foreign and the NRA had no direct access;
- Payments arrived from abroad (Booking remits from ABN AMRO Bank, Airbnb from the UK / Ireland) — Bulgarian banks did not “see” the counterparty as a platform;
- Tourist tax was a local matter and patent tax was filed largely on a voluntary basis.
From 1 January 2023 onwards (data first reported by 31 January 2024) the NRA receives a complete file on each host from every EU-registered platform — including name, TIN/PIN, IBAN, property address, cadastral number, amounts paid and commissions withheld. At the same time the NRA exchanges data with the other 26 Member States — so a Bulgarian tax resident with a property in Greece, Italy or Germany also falls within scope.
Scope of DAC7 — activities and platforms
The four “relevant activities”
Articles 143щ–143я TIPC capture four categories of activities performed via a digital platform:
- Rental of real estate — residential (apartments, houses, rooms), commercial premises, parking spaces;
- Personal services — remote or on-site work performed on demand (UpWork, Fiverr, DEEL, 99Designs, TaskRabbit, Bolt Food couriers);
- Sale of goods (eBay, Etsy, Amazon, Vinted, OLX);
- Rental of means of transport (Turo, GetAround).
Platforms in scope
Operators currently subject to DAC7 reporting:
- Short-term accommodation: Booking.com (Booking.com B.V., Netherlands), Airbnb (Airbnb Ireland UC), Vrbo / Expedia, Hometogo, Hostfully, Tripadvisor Vacation Rentals;
- Personal labour / freelance: UpWork, Fiverr, Freelancer.com, DEEL, 99Designs, TaskRabbit, Bolt Food (couriers), Wolt;
- Sale of goods: Amazon, eBay, Etsy, Vinted, OLX, Allegro, Zalando, Joom;
- Means of transport: Turo, GetAround, BlaBlaCar (for non-occasional use).
Reporting thresholds — mind the detail
A de minimis threshold exists only for the sale of goods:
- Sale of goods: the platform does NOT report a seller with fewer than 30 transactions AND under EUR 2,000 in total for the calendar year (both criteria must be met — cross either and the report is triggered);
- Short-term rental, personal services, vehicle rental: NO de minimis threshold. Even one EUR 30 night booked through Booking is reported;
- Large-hotel exemption: if the property has 2,000+ overnight stays per year under a single registration, it is treated as “exempt accommodation” and falls outside DAC7.
What data platforms report on a host
Platform operators collect and transmit to the NRA (or to the competent administration of the platform’s Member State of registration, which then exchanges with the NRA) the following data:
About the host (seller)
- Full name (individual) or corporate name;
- Primary address;
- Tax Identification Number (TIN) — for Bulgaria PIN (EGN) or company UIC (EIK);
- Issuing country of the TIN;
- Date of birth (individuals);
- VAT identifier (where available);
- IBAN to which payments are remitted;
- Country of registration (legal entity).
About the activity
- Address of the rented property;
- Cadastral number (Bulgaria — from the Property Register);
- Number of nights per quarter;
- Number of days listed (availability);
- Gross amounts received;
- Commissions and fees withheld by the platform;
- Other deductions (cleaning, deposit etc.);
- Currency of payments.
Reporting and deadline
Platforms report data on a quarterly breakdown for the previous calendar year by 31 January of the following year. Hosts may request a copy of the report from the platform (Booking and Airbnb supply a PDF extract through the partner account).
Important: the platform validates the host’s TIN through VIES (for UIC/VAT) or by direct verification of PIN with the NRA. If the host fails to provide a TIN, after two reminders the platform freezes payouts and may close the account.
Specifics for Booking, Airbnb and other platforms
Booking.com — Netherlands Reporting Platform
Booking is registered in the Netherlands (Booking.com B.V., Amsterdam) and files its DAC7 report with the Dutch tax administration (Belastingdienst), which automatically forwards it to the NRA for any host with a Bulgarian TIN or a Bulgarian-located property. Booking collects host verification through its “Partner Hub”.
Booking charges a commission of around 15–18% of the booking value, withheld before remittance to the host. For VAT purposes: the host is a taxable person receiving a service from another Member State and is required under Art. 97a VAT Act to register for the special VAT regime (intra-EU receipt only), within 7 days before the first received service. The host self-charges 20% VAT on the commission (reverse charge) and files a monthly VAT return.
Airbnb — Ireland Reporting Platform
Airbnb Ireland UC reports DAC7 to the Irish Revenue Commissioners, which forwards to the NRA. Airbnb commissions are typically 3% on the host side + 14–16% service fee on the guest side. The host is also required to register under Art. 97a VAT Act.
Vrbo / Expedia Group
Vrbo is part of Expedia Group, registered in Switzerland for EU operations. DAC7 reporting is performed via Expedia Lodging Partner Services GmbH, established in Germany, filing with the German BZSt and onward to the NRA.
Multiple platforms — double reporting
A host using Booking, Airbnb and Vrbo simultaneously for the same property will be triple-reported to the NRA. This is not an error — it is by design. The NRA consolidates the data and matches it against the host’s annual return under Art. 50 PITA or against the patent declaration.
Host duties towards Bulgarian authorities
1. Categorisation under the Tourism Act (Art. 113)
The property must be categorised before the first night. For apartments / houses / rooms a simplified regime applies (1 or 2 stars for “guest room” or “guest apartment”). Application is filed with the municipality of the property, fee EUR 25.57–200, issuance within 60 days. The certificate is valid for 5 years.
2. BULSTAT registration (individuals)
An individual carrying out business activity through rentals registers in the BULSTAT Register at the Registry Agency — fee EUR 7.67. The result is a 9-digit code used before the NRA and local authorities.
3. VAT registration under Art. 97a VAT Act
Because Booking / Airbnb provide a service (commission) from another Member State, the host — as a VAT taxable person — is required to register for the special regime. Deadline: 7 days before the first received service. No input VAT deduction unless under the general regime. A monthly return is mandatory even with zero turnover.
4. Choice of taxation regime
| Regime | Conditions | Amount |
|---|---|---|
| Patent tax (Art. 61з LTFA) | Up to 1 property; turnover < EUR 25,565 yearly; no general VAT registration under Art. 96 | EUR 12.78–127.82 per room per year |
| PIT — business activity | Above threshold or multiple properties | 10% PIT (with 25% statutory deductible — effective 7.5%) + social + health contributions |
| EOOD/OOD | High turnover, multiple properties | 10% CIT + 5% dividend = 14.5% combined |
5. Tourist tax in the municipality
Art. 61р LTFA — local tax of EUR 0.10–1.53 per night, set by municipal council. Monthly return filed in the municipality by the 15th of the following month.
6. Annual tax return
By 30 April of the following year — annual tax return under Art. 50 PITA (business activity) or confirmation of the patent declaration. Pay social and health contributions as a self-insured person.
DAC7 data vs filed return — how the NRA finds mismatches
The real risk of DAC7 is not the exchange itself — it is the automated cross-check between:
- The file received from platforms (Booking, Airbnb, Vrbo);
- The host’s annual tax return;
- The patent declaration in the municipality;
- The tourist tax filings;
- The Property Register (cadastral number);
- Art. 97a VAT registration records;
- Banking flows (interbank RTS).
Typical mismatches that trigger an audit:
- Host received EUR 18,000 from Booking but the patent declaration shows only 1 room (EUR 25/yr);
- Host declared “long-term lease” (potentially exempt under Art. 13 PITA) but DAC7 shows 240 overnight stays;
- Host received amounts above the VAT threshold (EUR 51,130 / BGN 100,000) and failed to register under Art. 96 VAT Act;
- The DAC7 address does not match the categorisation certificate;
- Host failed to file an annual return but Booking reported EUR 8,000 of income.
Sanctions for mismatches
- Art. 80 PITA: EUR 10–500 for filing a false return;
- Art. 124(1) TIPC: EUR 200–500 for failure to provide information;
- Art. 178 VAT Act: EUR 250–5,100 for failing to register under Art. 97a;
- Art. 81 PITA: tax due plus interest (base rate + 10 p.p. annually);
- For “significant scale” — Art. 255 CC (tax fraud), 1–6 years imprisonment. See our article on criminal liability for tax fraud.
Special cases — foreigners, co-ownership, automation
Host — foreign individual with Bulgarian property
A foreigner renting out a Bulgarian property through Booking falls into DAC7 via their country of residence (e.g., Germany). At the same time, they owe Bulgarian-source income tax (Art. 8 PITA — income from Bulgarian sources). Double taxation is avoided through the relevant DTT.
Bulgarian resident with foreign property
A Bulgarian tax resident (see tax residency) renting a property in Greece, Italy or Croatia through Airbnb declares the income under Art. 50 PITA in Bulgaria (worldwide income principle). DAC7 channels the data from the host Member State through the platform’s reporting jurisdiction to the NRA.
Co-owned property
Two spouses jointly own an apartment let through Booking. The platform reports a single IBAN. Solution: both must declare a proportional share in the annual return (Art. 13(5) PITA). Patent tax is also apportioned.
Property manager automation
If a host uses a property management company (channel manager), the platform reports the host (owner), not the management company. Settlements with the manager are internal (management agreement, typically 15–25% fee).
Comparison — obligations before and after DAC7
| Aspect | Until 2022 | After DAC7 (2023+) |
|---|---|---|
| Visibility to the NRA | Minimal, only via audit | Full automatic feed |
| Filing | Largely voluntary | Under DAC7 file scrutiny |
| Tourism Act categorisation | Often skipped | Increased CPC and municipal control |
| VAT Art. 97a | Rarely complied | Cross-checked with DAC7 — mandatory |
| Tourist tax | Often undeclared | Cross-checked with DAC7 nights |
| Social + health | Often “invisible” | Mandatory in business activity |
| TIPC prescription | 5 / 10 years | Same — but evidence comes earlier |
Short-term rental property — legal and tax review
From categorising the property and registering in BULSTAT, through Art. 97a VAT registration and the choice of optimal regime (patent / PIT / EOOD), to a cross-check of the DAC7 file against your filed returns — the Innovires team helps hosts maintain profitability with full legal certainty. Where a mismatch has been identified, we develop a remedial filing strategy and audit defence. Reach out before filing the 2026 annual return — the platforms’ data is already with the NRA.