We reconstruct transaction histories, distinguish wallet transfers from disposals and review the tax treatment of trading and more complex crypto activity.
A client came to ARG with information about Bulgarian crypto taxation but remained unsure how the rules applied to their own transactions. ARG reconstructed the relevant activity, identified the tax exposure and organised the supporting evidence.
That work clarified which items were still outstanding and how they related to the chosen tax treatment. The same distinction matters for any individual who has bought, held, exchanged or sold cryptoassets, especially where exchange records, wallet movements and complex activity appear together.
ARG can help when you need to
Provide the reporting year, countries where you lived and any foreign tax returns. Bulgaria's taxing rights depend on residence and income source; an exchange address or residence permit alone does not settle them.
Describe trading, mining, rewards and any services to clients. Personal disposals, business income and remuneration can follow different calculations, return appendices and deadlines, even when all payments involve tokens.
Collect complete exchange exports, wallet records and acquisition evidence, including earlier years. Each disposal needs a supportable value and cost, while transfers between your own wallets must be linked to prevent double counting.
Ordinary personal disposals normally use Appendix 5 and the 30 April deadline. The 5% discount requires electronic filing and payment by 31 March, no enforceable public debt and observance of the statutory cap.
For an individual investing their own money, Bulgarian crypto taxation starts with the transactions completed during the calendar year. The value shown in your portfolio is not, by itself, your taxable income. A sale or exchange can produce a realised gain or loss even when you leave the proceeds on an exchange. Before calculating that result, establish whether Bulgaria taxes you as a resident on worldwide income or as a non-resident on income from Bulgarian sources, and whether your activity is personal investment or a business.
A cryptoasset is a digital representation of value or a right that can be transferred and stored electronically through distributed ledger technology or similar technology. This definition comes from Article 3(1)(5) of Regulation (EU) 2023/1114, known as MiCA, and is used in the Bulgarian cryptoasset framework. It describes the asset; it does not decide every tax consequence. Bitcoin purchased as an investment, tokens received for work and assets traded through an organised business may require different income classifications. MiCA definitions
Article 33(3) of the Personal Income Tax Act, usually abbreviated to ЗДДФЛ in Bulgarian, covers sales and exchanges of financial assets, including cryptoassets. For transactions falling within that rule, calculate the gain or loss on each disposal, total the realised gains and losses for the year, and reduce the positive net result by the statutory 10% expense allowance. Article 33(4) starts the transaction calculation with the selling price less the relevant acquisition price. The allowance is part of the statutory calculation, rather than an invitation to select whichever expense figure produces the lowest tax. Article 33 amendment introducing the allowance
Suppose qualifying disposals produce gains of €12,000 and losses of €4,000 during a year reported in euro. The net result is €8,000; after the 10% allowance, the taxable income from those disposals is €7,200. The ordinary 10% personal income-tax rate would produce €720 before considering any applicable adjustments or relief in the full annual return. This illustration assumes personal investment falling under Article 33, documented acquisition values and no applicable exemption. It cannot be used unchanged for a trading business or for tokens received as remuneration.
The distinction between proceeds and profit is important. An exchange withdrawal of €20,000 does not show how much income is taxable: part might represent your original investment, previously realised proceeds or transfers between accounts. Equally, making no bank withdrawal does not establish that no taxable transaction occurred. The supporting schedule must follow the sales and exchanges themselves, including transactions where the consideration was another cryptoasset.
Selling a token for euro is a disposal. Exchanging one token for another also requires review under the sale-or-exchange rule, even if no conventional currency changes hands. Paying for goods or services with cryptoassets should be identified separately so that the transfer of the asset and the value received can be assessed. A payment card linked to a crypto account may trigger an underlying conversion that does not look like a trade in the card statement.
A genuine transfer between wallets belonging to you, with no change in beneficial ownership and no exchange for another asset, is different. Keep the sending and receiving addresses, transaction hash, quantity and evidence linking both wallets to you. Those records allow the transfer to be removed from the disposal schedule without losing the acquisition history. Network fees, wrapping, bridging and protocol deposits need their own entries: the platform label alone cannot establish that every movement was a simple transfer.
Merely acquiring or holding an asset does not create a sale or exchange under Article 33. Nevertheless, records from a purchase several years earlier may be essential when you eventually sell. Assets received by inheritance, legacy or gift also need their acquisition documents because the exemption and acquisition-price rules cannot be inferred from a zero amount in an exchange export. The NRA identifies the statutory inheritance-related exception when explaining the usual taxation of cryptoasset disposals. NRA guidance on cryptoassets
The Commercial Act uses the concept of a trader for a person carrying on specified commercial activities professionally or operating an enterprise whose nature and scale require commercial organisation. Registration as an individual sole trader is not the only relevant fact. Under Article 26(7) of the Personal Income Tax Act, an individual who conducts business as a trader may fall under the business-income rules even without that registration. Organised mining, dedicated equipment, services to customers, personnel and the overall manner in which the activity is conducted are relevant to this assessment.
That classification can change the calculation, accounting records, tax rate, return appendix, filing period and insurance analysis. Frequency alone is not a substitute for examining the activity. Bring a description of what you do, how you earn, which resources you use and whether you act for anyone else, alongside the transaction history. If the assets belong to a company, its profits must be reviewed under the corporate-tax and accounting framework; the individual 10% expense allowance is not a company deduction.
MiCA authorisation is another separate question. Investing your own assets does not automatically mean you provide a cryptoasset service to clients. Conversely, preparing a personal tax return does not authorise custody, exchange, advice or another regulated service for customers. Where your activity includes clients, ARG can coordinate the tax work with a separate regulatory review of the actual services and authorisation route. This keeps the return, business structure and operating permissions aligned with what you actually do.
Tell us where you live, how your business works and what you want to change. We will help you identify the questions to resolve and the next steps to consider.
Start with the relevant calendar year, your residence position and a complete inventory of the platforms and wallets used. For someone who has moved to Bulgaria, the date of arrival is only one fact: homes, family, work, time spent in each country and any applicable double-tax treaty may affect the residence analysis. A Bulgarian bank account, residence permit or exchange profile does not by itself determine which country can tax the income. Tell ARG if another country already expects a return or has taxed the same transactions so that the reporting can be coordinated.
Download original exports while you still have access to each account. A dashboard screenshot may confirm a balance, but it rarely records the acquisition cost, execution time and consideration for every disposal. Collect trade history, deposits, withdrawals, conversions, rewards and fee records separately where the platform provides different reports. Include closed accounts and assets held outside exchanges. The opening position matters just as much as the year's trades when assets acquired earlier were sold during the year.
Reconcile the quantity of each asset from the opening balance through purchases, receipts, transfers and disposals to the closing balance. If the same transfer appears as a withdrawal on one platform and a deposit on another, link the two records before calculating gains. Otherwise, software may count a disposal twice or treat an incoming transfer as free income. Record genuine discrepancies explicitly: an unexplained difference should lead to another document request, not to an invented acquisition price.
Where an exchange has closed or an account is inaccessible, combine whatever evidence remains: previous exports, transaction confirmations, bank records and public blockchain data. A blockchain record can establish an on-chain movement, but it may not establish who owned an exchange account, the legal purpose of a payment or the price of an off-chain purchase. ARG can help organise that evidence and identify which missing facts materially affect the return. A reconstruction should explain its sources and valuation choices sufficiently clearly for another person to follow it.
Keep a distinction between the currency used to prepare the tax return and the currency used to pay the liability. NRA euro-transition guidance states that returns for 2025 income filed in 2026 use lev amounts, while returns for 2026 income filed in 2027 use euro amounts. Public liabilities paid to the NRA after euro introduction are paid in euro. This matters when a platform exports everything in dollars or when you are correcting an older year: do not convert every historic column merely because the return is submitted after the currency change. NRA guidance on reporting periods and euro payments
A token-for-token swap needs a supportable monetary value at the relevant transaction time. Preserve the executed trade price where available and document the source used for any reconstruction. The closing market value on 31 December is not a substitute for the value of a disposal in June. Different exports may use different time zones or rounding methods, so resolve those differences before relying on an automated tax report. The final schedule should show how each reported number connects to a transaction and an underlying record.
For ordinary individual cryptoasset disposals under Article 33, the income is reported in Appendix 5 of the annual return under Article 50 of the Personal Income Tax Act. The normal filing period is 10 January to 30 April of the following year, with payment of the balance due by the applicable annual deadline. The NRA states that no advance tax is due for this disposal category. A person whose activity is taxed as a trader instead follows the relevant business rules, including Appendix 2 and the 1 March to 30 June filing period. Classification must therefore come before choosing the form and calendar. NRA annual income-tax guidance
The 5% early-filing discount requires electronic submission by 31 March, payment of the tax balance by 31 March and no public liabilities subject to enforced collection at the time of filing. The reduction is capped at €255.65, corresponding to BGN 500 for the relevant lev-denominated reporting context. These are cumulative conditions. Filing early without paying on time, or filing on paper, does not satisfy them. Check the taxpayer's NRA account and calculate the eligible reduction before making the payment; do not assume that an apparently small unpaid liability is irrelevant.
Electronic filing uses the NRA portal with an appropriate personal identification code, known as ПИК, or qualified electronic signature, known as КЕП. If someone files on your behalf, arrange the appropriate representation and access in advance. You should not have to hand over a wallet seed phrase or private key to support a tax return: transaction exports and ownership evidence should be supplied without granting control over your assets. After filing, keep the submitted return, confirmation of acceptance, payment evidence and the calculation behind it.
The prefilled return does not remove your responsibility to check completeness. Foreign exchanges, self-custody wallets and decentralised protocols may not appear in the expected form, and a platform's report may use a different tax methodology. Compare the return with the final transaction schedule and your other income. An accurate crypto schedule can still lead to an incomplete personal return if salary, rent, foreign dividends or another reporting obligation has been omitted.
If you have missed the deadline, establish which years are affected and submit the outstanding return through the applicable procedure. Late filing and late payment are separate issues: interest on unpaid tax and any filing sanction need to be assessed alongside the principal liability. Do not move an earlier year's disposal into the current year to make the records appear current. The NRA's late-filing guidance expressly tells taxpayers to file despite missing the deadline. NRA guidance on late returns
For a return already filed, compare the original and revised calculations, identify the precise error and check the available correction route for that year. The annual correction opportunity and changes during an NRA procedure are not interchangeable. Preserve both versions and the reason for the amendment. If a request for information or audit has already arrived, provide it at the start of the engagement, together with its service date and response deadline, so that the reporting work fits the ongoing procedure.
Separate how an asset was earned from what happened when it was later sold. Tokens received for employment or services, mining rewards, staking rewards, lending returns and promotional distributions do not necessarily have the same legal character as an investment bought with your savings. A later disposal may raise a further question about acquisition value and how to avoid counting the same economic amount incorrectly. The label in an exchange export is a starting point for gathering facts, not the final legal classification.
For protocol activity, explain what you deposited, what rights you received, who could use the assets and how you could withdraw them. Preserve the protocol terms applying at the time, the relevant transaction records and evidence of rewards or losses. Depositing tokens into a liquidity pool, receiving a receipt token, borrowing against collateral and being liquidated involve different rights and obligations. They should be reviewed separately rather than passed through one blanket “DeFi income” calculation. This approach also identifies whether a genuine loss, theft or platform failure has been confused with an ordinary disposal.
ARG can organise the records, prepare the factual transaction map and coordinate the accounting and legal decisions needed for the return. The useful result is a reconciled schedule, a clearly identified treatment for each category, the relevant return entries and a practical list of any further actions. Where the activity is a business or involves services to clients, the work should also address the associated accounting, insurance and regulatory obligations. Your next step is to provide the reporting year, residence background, platform list and available exports so that the scope follows your actual activity.
Compare the related procedures in this category, including their requirements and the stage at which you need them.
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