9% or 20% VAT on a One-Day Tour?

The situation is completely ordinary, and that's exactly why it's useful: a company sells a one-day tour — say, a guided visit to a landmark with lunch included — and the sale goes through an online tours-and-experiences platform such as GetYourGuide, Viator, Tiqets or Airbnb Experiences. The question that always comes first: is this 9% or 20% VAT?

The answer on the rate is short and stable. The answer on what the tax is charged on depends on a few facts that anyone selling such tours needs to check for themselves. Here is the whole logic, laid out so you can apply it to your own case.

As of today there is no legal basis for 9% on this service. The rate is 20%. The only open question is whether those 20% are charged on the margin or on the full price.

Three independent reasons lead to 20%, each of them sufficient on its own:

• The reduced 9% rate under Art. 66(2)(1) VAT Act covers accommodation only, in hotels and similar establishments. There is no accommodation in this tour.
• The special 9% rate for a general tourist service under Art. 136 and for excursions with occasional coach transport (the former item 6 of Art. 66(2)) expired on 30 June 2024.
• Lunch is also 20% — the reduced rate for restaurant and catering services was withdrawn on 31 December 2024.

1. The rates as of August 2026

The standard rate is 20% (Art. 66(1) VAT Act). The reduced 9% is an exception and is interpreted strictly — this is also the settled position of the Court of Justice of the EU under Art. 98 of Directive 2006/112/EC. Here's what stayed at 9% and what went back to 20%:

The exact wording of the repealed item 6 is telling: it referred to “the supply of a general tourist service in the cases under Art. 136(1), as well as excursions organised by tour operators and travel agents with occasional coach transport of passengers.” In other words, even when 9% existed, it hung on the Art. 136 regime or on a coach excursion — not on some generic notion of a “tourist package.” Today even that hook is gone.

2. A “package” under the Tourism Act ≠ a “general tourist service” under the VAT Act

This is where the most common mistake happens. The two concepts live in different laws, serve different purposes and do not overlap. The VAT rate does not depend on whether the service is a package under the Tourism Act.

Under the Tourism Act the tour is most likely not a package

• A package is a combination of at least two different types of tourist services for the purposes of the same trip. There are four types: carriage of passengers; accommodation; rental of a motor vehicle; and “any other tourist service.” An entry to a landmark and lunch are the same type — both are “other tourist service.”
• Even with transport included (transport + another service = two types) the regime still doesn't apply, because the package rules do not cover trips shorter than 24 hours without an overnight stay — an explicit exception deriving from Art. 2(2) of Directive (EU) 2015/2302 and reproduced in the Ministry of Tourism's guidance.
• There is also a 25 percent rule: one service of the “transport/accommodation/vehicle rental” type plus other tourist services is not a package if the other services are under 25% of the value and are not advertised as an essential element.

But under the VAT Act no package is required at all

Art. 136(1) VAT Act says nothing about a package. It is enough that a tour operator provides, in its own name, goods or services connected with a traveller's trip, using for that purpose goods or services bought from other taxable persons from which the traveller directly benefits. Then there is a single supply — a general tourist service.

The practical takeaway: a company may have no obligation whatsoever under the Tourism Act (a one-day tour with no overnight stay) and still fall within the VAT margin scheme. The reverse is also true. Don't mix the two analyses.

3. Decision tree

It all comes down to one question: does the company buy, from other taxable persons, the services the tourist directly benefits from — an attraction entry, restaurant lunch, transport from a subcontractor — and then sell them in its own name to the tourist?

Yes, at least partly → general tourist service (Art. 136)

20% on the margin. Invoice with no tax charged, self-charging by protocol, no input VAT credit for those costs. Own services are separated out and follow the general rules.

No, everything is an in-house resource → general taxation rules

20% on the full price. Full right to input VAT credit on the costs. The place of supply is in Bulgaria for all three elements.

Note: the rate is 20% in both branches. The difference is in the tax base, in the right to input VAT credit and in the documentation — and that difference matters for the company's cash result.

4. If it is a general tourist service — the mechanics

Important for the margin: the platform's commission (GetYourGuide, Viator, Airbnb Experiences and the like) is not a service the tourist directly benefits from — it is a selling cost of the company. It does not reduce the margin and does not fall within the prohibition in Art. 141. Where the company is VAT-registered on general grounds, input VAT on it is credited under the general rules. The same goes for advertising, accounting and software.

5. Case law of the Court of Justice of the EU

The special regime in Art. 136–142 VAT Act transposes Art. 306–310 of Directive 2006/112/EC, so the CJEU's rulings are directly relevant and are cited both by the revenue authority and by the Bulgarian courts.

6. The revenue authority's position

• Guidance No. M-24-36-11 of 19.04.2017 from the NRA's central office — the leading document on the topic. It clarifies the concepts of “traveller” and “general tourist service,” the scope of the regime after the restriction on supplies between tour operators was dropped on 01.01.2017, documentation by protocol, and the requirement for analytical accounting that allows the margin to be verified. It also refers back to the earlier Guidance No. UK-2 of 10.07.2012.
• Tourism Act status is irrelevant. The NRA accepts that a “tour operator” for VAT purposes is any taxable person carrying out such activity — registration under the Tourism Act is not required for the margin scheme to apply. So the fact that the company is not a registered tour operator does not take it out of Art. 136.
• Opinion on additional tourist activities (2017) — applies Art. 87a(2) of the Regulations: what is bought in goes on the margin, own activity goes under the general rules.
• Opinion No. 96-00-176 of 27.07.2018 — the rate on a general tourist service follows the place of supply of the services the tourist directly benefits from: 20% for Bulgaria and the EU, zero only for third countries.
• Guidance No. 20-00-100 of 29.06.2020 — interpretation of the reduced rate under Art. 66(2), useful for the scope of the concept of “accommodation.”

7. Bulgarian case law

Disputes right on the 9% / 20% borderline for tourist services exist from the period when the temporary reduced rate was in force. Two rulings sit directly on this question:

• Decision No. 765 of 11.12.2023 in administrative case No. 657/2023 — a dispute over whether a “package” tourist service is taxed at 9% under Art. 66(2)(6) VAT Act or at 20%; the reasoning discusses Art. 136 VAT Act and Art. 87a of the Regulations.
• Decision in administrative case No. 2832/2022 — a tax audit of a travel agency that had applied the reduced rate to combined tourist services.

To be honest: I cite these two rulings as reading material, not as settled practice — before anyone quotes them to a client or to the revenue authority, they should be read in full and checked for whether they have become final.

In substance they aren't even necessary for the answer: after 30 June 2024 the “9% or 20%” dispute is moot, because the reduced rate no longer exists. The case law is useful mainly for the period up to that date — if the company sold such tours earlier too, there may be an audit risk running the other way.

8. What the tax base depends on

The rate answer is settled — 20%. To know whether those 20% fall on the margin or on the full price, answer the following questions:

• Is transport included, and whose is it? An in-house coach with an in-house driver → general rules for that element (C-557/11 Kozak). A hired carrier → goes into the margin.
• Lunch — in whose name is the invoice? An invoice from the restaurant to the company → a bought-in service, goes into the margin. If the tourist pays for it on the spot → it isn't part of the company's supply at all.
• The landmark entry — does the company buy it? If yes — a bought-in service. If the tourists buy their tickets themselves, the company's service is only the guiding.
• Is the guide an employee or an external contractor? In-house resource → general rules. External, on a civil contract or invoice → goes into the margin.
• How exactly does the platform operate? GetYourGuide, Viator, Airbnb Experiences and the like run on different models — as an agent in the name and on behalf of the company (the company is the supplier to the tourist), or buying and reselling in their own name (the company is the supplier to the platform). Check it in the terms and in how invoicing is done.
• On what basis is the VAT registration? Under Art. 96 or only under Art. 97a. If it's only under Art. 97a — tax is charged by protocol on the commission, but there is no right to input VAT credit and no VAT is charged on sales.
• Are there also multi-day tours with an overnight stay? Then the package rules under the Tourism Act kick in — registration, tour operator's liability insurance, pre-contractual information.

9. Two side points worth flagging

The platforms — the self-charging is correct, but there's a trap further on

The commission a platform like GetYourGuide or Viator withholds is an intermediary service with its place of supply under Art. 21(2) and is self-charged by protocol under Art. 117 — that part is fine. The trap is in the opposite direction: if it turns out that the platform buys the tour in its own name and resells it, the company's supply is to a foreign taxable person — but for a general tourist service the place of supply remains Bulgaria under Art. 137. So Bulgarian VAT is due on the margin and there is no reverse charge. A supply to another tour operator is also a general tourist service after 01.01.2017.

A 2026 change to the taxable turnover

For the purposes of mandatory registration, a tour operator's turnover is now formed from the total amount received from the traveller, not just from the margin. If the company is not registered on general grounds, this can push it into registration much earlier than it expects. The provision is new — I'd recommend verifying it in the current wording before relying on it.

This text reflects the law and available case law as of 25 August 2026 and is for information only — it is not legal, tax or investment advice. Reduced VAT rates change often and on fixed deadlines, so before applying this to a specific case, check the current wording of the law at lex.bg and read the cited court rulings in full.

Sources

• VAT Act — Art. 66, 67, 96, 97a, 117, 136–142; VAT Regulations — Art. 87a
• Directive 2006/112/EC — Art. 98, Art. 306–310 (special scheme for travel agents, TOMS)
• Directive (EU) 2015/2302 on package travel — Art. 2(2)
• Ministry of Tourism — Guidance on applying the Tourism Act (concept of a package, the 25% rule, the under-24-hours exception)
• NRA — Guidance No. M-24-36-11 of 19.04.2017; Opinion No. 96-00-176 of 27.07.2018; Guidance No. 20-00-100 of 29.06.2020
• CJEU case law on Art. 306–310: C-552/17 Alpenchalets, C-763/23 Dragoram, C-163/91 Van Ginkel, C-220/11 Star Coaches, C-31/10 Minerva, C-308/96 Madgett & Baldwin, C-557/11 Kozak, C-200/04 iSt, C-380/16 Commission v Germany
• State Gazette issue 106 of 22 Dec 2023 — reduced-rate deadline of 30 June 2024