What the NRA Knows About My Income from Abroad. Part 3: The Taxable Event, Myths and Strategy

In part 1 we described the channels through which data reaches the National Revenue Agency (NRA). In part 2 we showed which payer reports what and what stays outside the NRA’s database. This part is practical: exactly when the tax liability arises, what the NRA can “read” into the data it has, and how to arrange the facts before someone else arranges them for you.

1. When income is “received”: the taxable event

The most widespread mistake is the belief that as long as the money is in the brokerage account or on the exchange there is no taxable event, and that one arises only when the money reaches the bank. The law says otherwise. Article 11 of the Personal Income Tax Act (PITA) reads (unofficial translation):

(1) Unless otherwise provided in this Act, income shall be deemed acquired on the date of: 1. payment – for payment in cash; 2. crediting of the account of the recipient of the income or receipt of the cheque – for non-cash payment; 3. receipt of the performance – for non-monetary income.

(2) In the cases of sale, exchange or other transfer for consideration of rights or property under Article 33(3), the income shall be deemed acquired as at the date of the transfer.

(3) Income shall also be deemed acquired by the individual where, on their instruction or under an agreement between them and the payer, the payment or the performance is received by a third party.

Article 33(3) PITA (as in force from 1 January 2026) covers the sale or exchange of shares, interests, compensatory instruments, investment vouchers and other financial assets, including crypto-assets, as well as trading in currencies other than the euro. The taxable income is the sum of the gains realised on transactions during the year, reduced by the sum of the realised losses, and reduced by 10% for expenses. The sale price also includes non-monetary consideration (paragraph 5). The acquisition cost of an asset received in an exchange is its market price at the time of the exchange (paragraph 6, item 6).

The conclusion: the taxable event is the sale or the exchange, not the withdrawal. Whether after the trade you keep the euros with the broker, on the exchange or in the bank makes no difference. The NRA’s PITA Handbook (sheet I.6) also notes that investment firms report the trade date, not the date on which the amount is received.

Situations

Situation	When the taxable event occurs	Legal basis
You sell shares, ETFs or crypto and the money stays with the broker or on the exchange	On the date of the sale	Article 11(2) and Article 33(3) PITA
You sell on 30 December and settlement is on 2 January	In the year of the trade	Article 11(2) PITA (the date of the transfer)
You swap BTC for ETH	On the date of the swap. The sale price is the market value of the ETH received, and that becomes the acquisition cost of the ETH	Article 33(3), (5) and (6)(6) PITA
You swap crypto for a stablecoin (USDT, USDC)	On the date of the swap. A stablecoin is a crypto-asset (under MiCA, including an e-money token), not fiat currency	Article 33(3) PITA; Regulation (EU) 2023/1114
You withdraw euros from the broker or the exchange to your bank	Not a taxable event: you are moving your own money	—
You move crypto between your own wallets	Not a taxable event. DAC8, however, reports it as a transfer, so keep evidence that both wallets are yours	—
A dividend credited to your brokerage account	On the date the account is credited; final tax of 5%, declared in the annual tax return	Article 11(1)(2); Article 38(1)(2)(b); Article 46(3); Article 50(1)(3)(a) and Article 67(4) PITA
Earnings accumulated in a platform balance (Upwork, YouTube and so on) that you have not yet withdrawn	Conservative reading: when the amount is available in your balance, i.e. it has been received by the platform as a third party under an agreement with you. If in doubt, ask for an official opinion	Article 11(1)(2) and (3) PITA
You receive a payment in crypto (from a client, a prop firm and so on)	On the date of receipt; the income is valued at the market price	Article 11(1)(3) and Article 10(4) PITA
Salary from a foreign employer	On the date of payment or of crediting of the account	Article 11(1) PITA

2. How the NRA “reads” the data it has

The data from part 2 is not a tax base in itself. In the gaps between the data, however, the NRA can give the facts an unfavourable context. Here are the most common conclusions and the legal tools behind them.

Gross proceeds as profit

Under CRS the NRA sees the gross proceeds from sales, and under DAC8 the annual totals of sales for fiat. If you do not provide the acquisition cost, the law has a ready answer: zero (Article 33(6)(3) PITA). The taxable base is then the entire turnover.

Balance growth as income

The balance at 31 December includes unrealised gains. If it grows year after year while your annual tax return shows nothing, for the inspector that is a discrepancy that needs explaining.

Every incoming payment as income

Own transfers between accounts, loans and gifts are not income. Gifts and inheritances are expressly not treated as income (Article 13(2) PITA). But if you cannot tell them apart with documents, the NRA will treat them as income. Loans above the thresholds in Article 50(1)(5) PITA (for the part outstanding at the end of the year, excluding loans from banks) must be declared in the annual tax return. Otherwise, besides the 10% fine under Article 80a PITA, you lose your strongest explanation.

Tax-exempt income as taxable

The NRA also receives data on income that is not taxed at all: sales of personal belongings on Vinted or eBay (Article 13(1)(2) PITA), interest on deposits with banks in the EU/EEA (item 8), trades on a regulated market (item 3). Without context, these amounts look taxable. The reverse trap: the yield on money market funds (for example Revolut’s “Flexible Cash Funds”) and interest on uninvested cash at brokers are not interest on a bank deposit and are taxed.

The special procedure (Articles 122–124 TSSPC)

When a person has not filed a return, when there is evidence of concealed income, or when the declared income does not match the person’s assets, the NRA can determine the tax base under a special procedure (Article 122(1) of the Tax and Social Security Procedure Code, TSSPC). When assets or expenses clearly and significantly exceed the declared means, taxable income is presumed until proven otherwise (Article 124 TSSPC). The burden of proof is yours. Income established in this way is taxed as income from “other sources” (Article 35(6) PITA).

An illustration: in judgment No. 1213 of 25 February 2022 in administrative case No. 10432/2021, the Administrative Court Sofia-City upheld a tax assessment issued under Article 122 TSSPC. In it, the undeclared receipts on the person’s accounts over four years were taxed under Article 35(6) PITA. The court rejected a contract and payment documents submitted at a later stage, finding that they had been created “precisely for the purposes of these proceedings”. The lesson: documents must exist when the transaction happens, not be created when the letter arrives.

VAT and social security

DAC7 and CESOP data show turnover. The NRA can compare it with the threshold for mandatory VAT registration (EUR 51,130 from 1 January 2026, Article 96 VAT Act) and with the obligation to register for services to business clients in the EU (Article 97a VAT Act). Income from a liberal profession is linked to self-insured status (§ 1(29) of the Supplementary Provisions of PITA). In other words, the same set of data can lead at the same time to income tax, VAT and social security contributions.

Tax residence

Under CRS and DAC8 the NRA sees the country of residence that you declared to your bank or exchange. If you declared Cyprus or the UAE while your life is in Bulgaria, the mismatch is visible. Under DAC8 a false self-declaration is also an offence in its own right, with a fine of EUR 1,000 to 3,000 (Article 278i(9) TSSPC).

Penalties and limitation

For not filing an annual tax return the fine is up to BGN 500 (EUR 255.65), and for incorrect data that leads to lower tax, up to BGN 1,000 (EUR 511.29). For a repeat offence the fines are up to BGN 1,000 and up to BGN 2,000 respectively (Article 80 PITA; the law still states the amounts in leva). On top of that come the tax itself and late-payment interest, and for large amounts criminal liability (Article 255 of the Criminal Code). The limitation period is 5 years from the end of the year in which the return should have been filed, with an absolute limitation period of 10 years.

3. Myths and reality

Myth	Reality	Legal basis
“I haven’t withdrawn the money to the bank, so there is no taxable event.”	The event is the sale or the exchange. The withdrawal is just moving your own money.	Article 11(2) PITA
“Swapping to USDT is not a sale.”	Swapping a crypto-asset for another crypto-asset, including a stablecoin, is an exchange under Article 33(3).	Article 33(3) and (5) PITA
“The NRA sees every transaction in Revolut.”	Automatically it sees the balance at 31 December and the gross interest, but not the individual transactions. It can request them, or ask you for them in an inspection.	TSSPC, Article 142b
“The NRA sees nothing in Revolut.”	Revolut Bank UAB is a Lithuanian bank and reports under CRS to Lithuania, which reports to the NRA.	TSSPC, Articles 142b–142v
“Until 2026 my crypto is invisible.”	There is no automatic exchange, but there is exchange on request (including group requests), the cash side of the transactions goes through banks, and the history stays with the exchanges.	DAC, Articles 5 and 5a
“Gross proceeds are not my profit; the NRA will understand that.”	If you do not prove the acquisition cost, it is zero.	Article 33(6)(3) PITA
“Tax was withheld abroad, so I’m done.”	A resident declares their worldwide income in Bulgaria. The tax paid abroad is deducted under the double tax treaty (DTT) or as a tax credit, if you prove it.	Articles 6, 75, 76 PITA
“Small amounts don’t need to be declared.”	There is no tax-free allowance for this income. Under DAC7, there is a threshold only for the sale of goods (30 sales and EUR 2,000).	PITA; Article 143ya9 TSSPC
“The platform is outside the EU, so it doesn’t report.”	Operators outside the EU register in an EU country; UK operators report under the DPI-MCAA.	DAC7; DPI-MCAA
“ETFs are always tax-exempt.”	Only trades on a regulated market in the EU/EEA are exempt. Trades on the NYSE or off-exchange are taxed.	Article 13(1)(3); § 1(11) of the Supplementary Provisions of PITA
“Everything that comes into my account is income.”	Gifts, inheritances, loans and own transfers are not income, but you must be able to prove it, and loans above the thresholds are declared.	Article 13(2); Article 50(1)(5) PITA
“Interest in Revolut is tax-exempt.”	Only interest on deposits with banks in the EU/EEA is exempt. Revolut’s “Flexible Cash Funds” are money market funds, and the income from them is taxed.	Article 13(1)(8) PITA
“I sell old clothes on Vinted and I’ll be taxed.”	Income from the sale of personal movable belongings is tax-exempt (with exceptions, e.g. vehicles held for less than 1 year, and works of art).	Article 13(1)(2) PITA
“A prop firm payout is a gain from trading financial instruments.”	Our position: it is income from a liberal profession, not under Article 33(3). We recommend getting it confirmed for the specific case.	§ 1(29) of the Supplementary Provisions and Article 29(1)(3) PITA
“The US doesn’t share data, so I won’t declare.”	The obligation to declare does not depend on the channel. The information comes on request, through EU subsidiaries and through the banks.	Articles 6 and 50 PITA; Bulgaria–US DTT

4. The strategy: staying ahead of the wind

1. Establish and document your tax residence. Your self-certification to banks, brokers and exchanges must match reality (Article 4 PITA; see the article on dual residence).
2. Get the documents before you need them: the brokers’ annual reports with the realised result; the full transaction history from the exchanges (CSV or API), especially for the years before 2026 and before you close an account; the DAC7 copy the platform sends you by 31 January; the documents for the tax withheld at source (Form 1042-S or a certificate from the foreign administration); a certificate of residence, if you apply a DTT; loan and gift agreements; statements for your own transfers.
3. Calculate correctly. The result is determined per trade, and for indistinguishable quantities at the weighted average price (Article 33(4) PITA). Losses reduce the gains for the year, and then 10% expenses are deducted (Article 33(3)). Check the place of execution: a regulated market in the EU/EEA means tax-exempt income.
4. Declare on time. The annual tax return is filed from 10 January to 30 April, and a one-off correction is possible until 30 September (Article 53(1) and (2) PITA). The return also declares holdings and property abroad (Article 50(1)(4)) and loans above the thresholds (item 5).
5. File the SPB-8 report with the Bulgarian National Bank (BNB) by 31 March if at 31 December your total claims on foreign persons (accounts abroad, financial loans granted, and securities acquired without a Bulgarian investment firm as intermediary) are at least EUR 25,000, or if your liabilities under financial loans received from foreign persons are at least EUR 25,000. The two thresholds are tracked separately (Article 10(2) Currency Act; Article 13 of BNB Ordinance No. 27; the euro threshold applies from 1 January 2026).
6. Check VAT and social security. The turnover the NRA sees under DAC7 and CESOP may mean an obligation to register for VAT and to pay social security as a self-employed person.
7. If you have missed something, correct it before the NRA does. A correction filed on your own initiative lets you present the data in your own context. Once an inspection or a tax audit begins, the NRA sets the context.
8. If the treatment is unclear, ask for an official opinion. Staking, platform balances and prop firm payouts are questions where a written request to the NRA head office costs less than a dispute.
9. If the letter has already arrived, see the article on the NRA tax residency check.

5. Frequently asked questions

The questions were collected from public discussions on social networks and forums (Reddit, the Upwork and Fiverr communities and others). The answers are based solely on the legislation and the sources for this article.

Does the NRA know about my Revolut account?

Yes. Revolut Bank UAB reports under CRS to Lithuania, and Lithuania to the NRA: the balance at 31 December and the gross interest, by 30 September of the following year. Individual transactions are not reported automatically.

Does the NRA know about my crypto on Kraken if I haven’t withdrawn anything?

From 2026, yes, under DAC8: annual totals per asset for purchases, sales, exchanges and transfers, whether or not you have withdrawn. The withdrawal makes no difference to the taxable event.

I sold BTC for USDT. Do I owe tax?

Yes, if there is a realised gain. Swapping a crypto-asset for a stablecoin is an exchange under Article 33(3) PITA.

I get money from TikTok or YouTube. Does the NRA know?

Yes. Content platforms report their creators. The income is declared in the annual tax return, and the tax withheld in the US is deducted if you have a document for it.

I sell clothes on Vinted. Will I be taxed?

If you sell 30 or more items, or for more than EUR 2,000, Vinted will report you. Income from selling personal belongings, however, is tax-exempt (Article 13(1)(2) PITA). Keep evidence that the items are personal and were not bought for resale.

Does Airbnb report my rental income?

Yes. Once a year Airbnb reports to Ireland the address, the nights and the amounts paid (broken down by quarter), and Ireland sends them to the NRA and to the country where the property is located.

I have an account with a US broker. Does the NRA know?

Not automatically: FATCA is non-reciprocal, and the US participates in neither CRS nor CARF. Your obligation to declare, however, is the same, and the information can be requested under the DTT.

Tax was withheld in the US. Do I still have to declare?

Yes. You declare the income and deduct the tax paid abroad, up to the amount of the Bulgarian tax (under the DTT or Article 76 PITA). The document for the tax withheld is your responsibility.

Revolut closed my account after a source-of-funds check. Is the NRA behind this?

No. This is the bank’s own check under the anti-money laundering rules. The documents you need there (contracts, statements, evidence of gifts and loans) are the same ones you will need with the NRA.

Fiverr and Upwork asked for my tax number. Why?

Because of DAC7. Without a tax number, the platform may stop payouts. The data goes to its tax administration in the EU and from there to the NRA.

Do I have to register for VAT because of Upwork?

It depends on the client and the place of supply. For services to business clients in the EU, registration under Article 97a of the VAT Act is required regardless of turnover. It is also mandatory when turnover exceeds the threshold in Article 96 of the VAT Act.

I have small and irregular income from YouTube. Is there a tax-free allowance?

No. With income from a liberal profession, the question of social security contributions also arises. That is why it is worth doing the numbers before the year, not after it.

Legislation and sources for part 3

• PITA, Articles 4, 6, 10, 11, 13, 29, 33, 35, 38, 46, 50, 53, 67, 75, 76, 80, 80a, § 1(11) and (29) of the Supplementary Provisions (lex.bg, in Bulgarian (opens in a new tab)); TSSPC, Articles 122, 124, 142b–142v, 142yu–142ya10, 143ya5–143ya13, 278i (lex.bg, in Bulgarian (opens in a new tab)); VAT Act, Articles 96, 97a; Currency Act, Article 10(2); BNB Ordinance No. 27, Article 13; Criminal Code, Article 255
• NRA – Virtual currencies (in Bulgarian) (opens in a new tab); DBR – The NRA explains how income from cryptocurrencies is declared and taxed, May 2026 (in Bulgarian) (opens in a new tab); KiK – NRA opinion of 29 August 2025 on the sale of crypto-assets (in Bulgarian) (opens in a new tab)
• NRA – PITA Handbook, sheet I.6 Acquisition of income (published in KiK, 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); NRA – TSSPC Handbook, sheet II.V.5 Audit under Article 122 (published in KiK, in Bulgarian) (opens in a new tab)
• KPMG – Changes in the personal income tax and insurance legislation, January 2024 (opens in a new tab)
• Administrative Court Sofia-City, judgment No. 1213 of 25 February 2022 in administrative case No. 10432/2021 (in Bulgarian) (opens in a new tab)
• BNB – press release on the reports of resident individuals, 25 March 2025 (in Bulgarian) (opens in a new tab)
• Regulation (EU) 2023/1114 (MiCA); Directive (EU) 2023/2226 (DAC8)

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.