What counts as an official business trip
A business trip is a temporary, short-term assignment of an employee or officer away from the place of work to perform a task assigned by the employer. The legal framework is in Art. 121 of the Labour Code for employment relations and in two Council of Ministers regulations on monetary compensation:
- Regulation on Business Trips in the Country (Decree 72/1986, last amended by Decree 354/2025, in force from 1 January 2026).
- Regulation on Official Business Trips and Specializations Abroad (Decree 115/2004, last amended by Decree 9/2025, in force from 1 February 2025).
Additional tax laws: Art. 33 CITA (corporate deductibility) and Art. 24(2)(5) PITA (employee exemption).
Business trip vs posting of workers. A “business trip” (командировка) is short-term travel to perform a task within the existing employment relationship with the same employer. “Posting of workers” (командироване) is sending an employee to provide services to another employer in Bulgaria or the EU under Directive 96/71/EC — with different legal treatment, A1 certificates and other obligations. See our separate articles on posting to Germany (MiLoG) and posting of workers in the EU.
Domestic business trips (from 1 January 2026)
Per diems
Under Decree 354/2025, in force from 1 January 2026, the former BGN amounts are converted to euros:
| Type of trip | Until 31.12.2025 | From 1.1.2026 |
|---|---|---|
| With overnight stay (per day) | BGN 40 | EUR 22 |
| Without overnight stay (per day) | BGN 20 | EUR 11 |
The increase (EUR 22 ≈ BGN 43 at the fixed rate of 1.95583) reflects a real rise of around 8% and is the first significant update in more than a decade.
Accommodation
Accommodation is reimbursed against a document (invoice/receipt) for actual costs for one night. Limits are set in the regulation and depend on the rank of the employee and the locality. In practice, this is the actual price of a mid-category hotel.
Travel costs
- Public transport: tickets are reimbursed — train (2nd class or couchette), bus, plane (economy class for short destinations).
- Own vehicle: subject to employer authorisation. Compensation per kilometre, typically EUR 0.35–0.50/km (set in the travel order).
- Company vehicle: fuel and depreciation borne by employer against invoices.
Business trips abroad
Per diems (Appendix 2)
Appendix 2 of the Regulation sets per diems by country. The 2026 range is:
- EUR 35 — most Balkan countries and developing economies;
- EUR 50–60 — most Western and Northern European countries;
- EUR 80 — United States and Canada.
The current rate for a specific country is verified in Appendix 2. Per diems are payable for each full day of the trip, including travel days.
Accommodation
Accommodation is reimbursed against invoice for actual costs, but not exceeding the approved limits in Appendix 2 per country. The limit tends to be 2–3 times the per diem. Hotels above the limit — the excess is borne by the employee or treated as additional taxable income.
Travel and transport
- Air tickets — economy class as a rule; business class for flights over 6 hours with express authorisation.
- Train — 1st or 2nd class depending on rank.
- Transport in the destination city — reimbursed against documentation (metro tickets, bus, taxi with justification).
- Medical insurance for the travel period — from 1 February 2025 reimbursable under the Regulation (previously debated).
Currency of payment
From 1 February 2025 all amounts in the regulation are denominated in EUR. Payment in another currency is allowed at the Bulgarian National Bank rate on the payment day.
Required documentation
Documentary discipline is critical — during an audit the NRA demands a full set per trip. A missing document can turn the entire expense into non-deductible.
Before the trip
- Travel order (form) — contains employee name, purpose, destination, period, transport, authorised expenses, funding source. Issued BEFORE the trip.
- Budget estimate — for large trips.
- Transport and hotel bookings.
During the trip
- Keep all invoices and receipts (fuel, hotel, transport, taxi).
- Boarding passes (evidence of actual travel).
- Meeting materials (business cards, minutes).
After return
- Trip report within 3 days — description of activities performed, outcomes and accompanying documents.
- Expense report with invoices and receipts.
- Return of unused advance payments (if any).
Tip: Original travel order and report are kept in the company file for at least 10 years — through the limitation under Art. 171 DOPK. See our article on limitation.
Corporate tax deductibility (CITA)
Art. 33 CITA sets out the conditions for deductibility of travel expenses:
- The trip is for a business purpose and is documented.
- Expenses do not exceed the regulated limits.
- A travel order exists before the trip begins.
- Primary documents exist (invoices, tickets, receipts).
Three scenarios
| Scenario | CITA | PITA |
|---|---|---|
| Within the regulated limit | Deductible | Exempt |
| Above limit but up to 2× limit | Deductible | Exempt |
| Above 2× limit | May remain deductible, but excess is taxable income | Taxable for the employee (10% PIT) |
Example: on a domestic trip the employer pays EUR 44 per day (double limit). The expense is fully deductible for the company and exempt for the employee. If it pays EUR 50 — EUR 44 are exempt and EUR 6 are taxable at 10%.
Non-deductible expenses
- Expenses without a travel order.
- Expenses above the limit without documentation of the actual amount.
- Expenses for family members accompanying the employee.
- Personal consumption (minibar, entertainment).
Exempt income of the employee (Art. 24(2)(5) PITA)
For the employee, travel allowances are not taxable, provided:
- Per diems — exempt up to twice the regulated amount. Domestic: up to EUR 44/day (with overnight). Abroad: up to EUR 70–160/day depending on country.
- Accommodation — exempt at actual amount against document; no PITA cap (but subject to the regulation’s limit for employer recognition).
- Travel — fully exempt, against document.
Amounts above 2× per diem are taxable — 10% PIT is withheld by the employer and transferred to the NRA by the 25th of the following month.
Business trips by owners and managing directors
For managers and partners with a management contract (ДУК) the regime is the same. Without such a contract — and for an owner/partner not on an employment contract — payment of per diems requires specific treatment:
- Payment is possible only when the person acts in the capacity of manager or representative of the company.
- Documentation: travel order + report as for any employee.
- Tax treatment: per diems are exempt up to 2× the regulated amount (Art. 13(1)(23) PITA).
- Excess — taxable income (10% PIT).
Elements verified in an audit: frequency of “trips” (irregular and unreasonably frequent travel by the owner may be classified as hidden profit distribution), content of reports, link to company activity.
Common mistakes in audits
- No travel order before the trip. A subsequent “accounting” order is not acceptable — the entire expense becomes non-deductible.
- Generic purpose description. “Business needs” or “work meeting” without specifics does not survive audit. Mandatory — partner, purpose, expected outcome.
- No report after return. Without a report, the NRA suspects a partial or absent business purpose.
- Invoices in the employee’s name, not the company’s. Hotel invoices must be issued to the company — especially for VAT credit.
- Personal expenses included. Restaurant with family members, excursions, souvenirs — not deductible.
- Double payment. Per diem + meal reimbursement against invoice — not allowed. The per diem covers meals.
- Excessively long trips. Over 30 days domestically or 60 days abroad are often reclassified as a permanent change of workplace, not a trip.
- Recurring trips to the same site. May be treated as a permanent workplace — especially in construction and consulting.
The regulations are available at lex.bg. Current abroad per diems (Appendix 2) are published in the State Gazette upon each change.
Travel policies and CITA audits
From drafting internal travel rules to defending an audit — the Innovires team supports companies through the full process. Consultations on orders, reports, tax deductibility and employee exemptions. Contact us for a policy review or when an NRA audit begins.