What the NRA Knows About My Income from Abroad. Part 2: The Payers

In part 1 we described the channels: DAC1, CRS, DAC7, DAC8, CESOP, exchange on request and the big exception, the US. Here we turn the perspective around. We do not ask “what does each channel carry” but “who pays me, and what of it reaches the National Revenue Agency (NRA)”. The answer depends above all on the type of payer and on which company is the party to your contract.

1. How to read the table

• Type of payer: the group to which whoever pays you or holds your money belongs.
• Key examples: the most common names. The companies listed are as at the date of the article. The corporate structures of platforms and brokers change, and everyone should check which company is currently the party to their own contract (in the terms and conditions and the client agreement).
• Channel and provision: under which act and which provision of the Tax and Social Security Procedure Code (TSSPC) or the VAT Act the information travels.
• When it reaches the NRA: how often and by what date.
• The NRA has / The NRA does not have: what actually ends up in the NRA’s database and what you have to prove.

2. The big table

* The companies and countries listed are as at 28 October 2026. Corporate structures change. Check which company is currently the party to your contract.

3. Notes by group

Employers

For a salary from an EU country, the NRA usually receives the gross amount under DAC1 with a delay of a year to a year and a half. The dispute is almost always about the days, not the amount. If the work was performed in Bulgaria, it is taxable here, wherever the employer is based (Article 8(2) PITA). Keep a calendar of where you were, a certificate of the tax paid abroad and, where applicable, an A1 certificate for social security.

Clients under direct contracts

This is the weakest automatic channel. It shows up mainly through CESOP and the CRS balance. Here, however, there is a second risk besides income tax: VAT. Services to business clients in the EU require registration under Article 97a of the VAT Act regardless of turnover, and turnover above the threshold in Article 96 (EUR 51,130 from 1 January 2026) requires mandatory registration. CESOP was created precisely for VAT.

Platforms

The platform sends you a copy of what it reported by 31 January. This is literally the information the NRA will compare with your annual tax return. Check it: the amounts per quarter, the number of transactions, the fees. If the copy contains a mistake, such as someone else’s payments or double counting, ask the platform for a correction and keep the correspondence.

Content creators

YouTube, TikTok, Meta, OnlyFans and Patreon report their content creators. OnlyFans (Fenix International Ltd) reports under DAC7 for periods from 2023. From what we have seen in practice since 2025, Fenix International also provides information going back up to 6 years, i.e. through exchange on request. The amounts the NRA sees may be after the platform’s fee but before the tax withheld in the US. That is why the document for the tax withheld (Form 1042-S) matters for the tax credit.

Brokers

Under CRS the NRA sees the gross proceeds from sales, not the profit. Without a report of the realised result, the NRA has no way of knowing the acquisition cost, and under the law, without a document the acquisition cost is zero (Article 33(6)(3) PITA). The second important check is the place of execution of the trade. Only trades on a regulated market in the EU/EEA are tax-exempt (Article 13(1)(3) in conjunction with § 1(11) of the Supplementary Provisions of PITA). A US stock exchange is not such a market, and many brokers execute orders off-exchange.

The US

The absence of automatic exchange is not an exemption from tax. It means the information will come another way: on request under the DTT, through the EU subsidiary, or through the bank to which you transfer the money. And then it will come without the context you could have provided yourself.

Crypto

For 2026 the NRA will receive annual totals per asset. They show how much fiat you put in and took out with that provider, but not the acquisition cost of assets brought in from another exchange or from your own wallet, nor your purchases in past years. If you cannot prove the acquisition cost, you risk it being taken as zero. That is why your transaction history needs to be downloaded now, while the platform still keeps it.

Banks, Revolut and e-money institutions

Under CRS the balance at 31 December and the gross interest are visible, but not the individual transactions. So the NRA does not automatically know exactly what went through the account. It can, however, request the full statements, and in an inspection it will ask you for them too. Then you need to be able to separate your own transfers, loans, gifts and income. Cash loans must be declared in the annual tax return when the part of the loans received or granted during the year that is still outstanding at year-end exceeds BGN 10,000 (EUR 5,112.92) in total, or when the outstanding balances of the loans for the last 6 years exceed BGN 40,000 (EUR 20,451.68) in total (Article 50(1)(5) PITA). Loans from banks are not declared. Otherwise the fine is 10% of the undeclared amount (Article 80a PITA), and the incoming money looks like income of unclear origin.

Watch out with “interest”. Only interest on deposits with banks in the EU/EEA is tax-exempt under Article 13(1)(8) PITA. The yield on Revolut’s “Flexible Cash Funds” (money market funds through Revolut Securities Europe UAB), as well as interest on uninvested cash at Wise, Trading 212 or Interactive Brokers, is not interest on a bank deposit, and the exemption does not apply to it.

P2P platforms

The balance and the gross interest do not show the losses from defaulted loans. Download the platform’s annual statement for the net result and the written-off receivables.

Prop firms

Payouts from a prop firm are not income from transactions in financial assets under Article 33(3) PITA. Trading usually takes place on a simulated account, and the trader does not dispose of their own financial assets. Our position is that this is income from a liberal profession (§ 1(29) of the Supplementary Provisions of PITA), with statutory deductible expenses of 25% (Article 29(1)(3) PITA) and self-employed social security under the Social Security Code. This presupposes registration in the BULSTAT register and self-insured status (§ 1(29)(c) of the Supplementary Provisions of PITA). Since the foreign prop firm does not withhold tax, the person pays quarterly advance tax themselves by the end of the month following the quarter; no advance tax is paid for the fourth quarter (Article 43(1) and Article 67(1) and (2) PITA). We recommend discussing each specific case with an accountant or sending a written request to the NRA head office to confirm the interpretation.

4. What the NRA does not have, in summary

• The acquisition cost. Neither CRS nor DAC8 carries it. Under Article 33(6)(3) PITA, without a document the cost is zero.
• The realised result per trade and the losses, which under Article 33(3) PITA reduce the gains for the year.
• The tax paid abroad. As a rule, CRS and DAC1 do not carry it; DAC7 carries only what the platform itself withheld.
• The expenses of the activity.
• The nature of the incoming money: own transfer, loan, gift from a relative (not income, Article 13(2) PITA), sale of a personal belonging, a refund.
• The difference between unrealised gains and income in the CRS balance.
• The individual transactions. Everything automatic is aggregated: balances, annual totals, quarterly amounts.
• Crypto history before 2026, balances in self-hosted wallets and DeFi (except on request).
• Automatic data from the US.
• The facts about your tax residence: the days, the home, the family, the centre of vital interests. Under CRS and DAC8 the NRA sees only what you declared to the financial institution.

It is precisely in these gaps that the NRA starts to interpret. In part 3 we show how that happens, when income is “received”, and how to arrange the facts so that the interpretation is yours.

Legislation and sources for part 2

• PITA, Articles 8, 13, 29, 33, 43, 50, 67, 80a, § 1(11) and (29) of the Supplementary Provisions (lex.bg, in Bulgarian (opens in a new tab)); TSSPC, Articles 142b, 142yu–142ya10, 143z, 143ya5–143ya13 (lex.bg, in Bulgarian (opens in a new tab)); VAT Act, Articles 96, 97a, 123a
• Airbnb – DAC7 (opens in a new tab); Upwork – DAC7 (opens in a new tab); Patreon – DAC7 (opens in a new tab); BTTP – OnlyFans and DAC7 (opens in a new tab)
• Kluwer International Tax Blog – DAC7 and Digital Content Creators (Desmyttere, Vázquez, 2024) (opens in a new tab)
• KiK – NRA opinion on selling shares on an unregulated foreign market (in Bulgarian) (opens in a new tab); NRA – PITA Handbook, sheet I.8 Tax-exempt income (published in KiK, in Bulgarian) (opens in a new tab)
• IRS, Rev. Proc. 2022-35 (opens in a new tab); Irish Revenue – CARF and DAC8 reportable jurisdictions (opens in a new tab)

This article is for information only and does not replace individual advice. The legislation is stated as at 28 October 2026. Amounts that the laws still state in leva have been converted at the fixed rate of BGN 1.95583 to EUR 1.