Comments on ECJ C-429/23: VAT Deduction Refusal for Pre-registration Invoices

The Bulgarian company NARE-BG acquired land for construction, receiving invoices from subcontractors with a total VAT of approximately EUR 60,050 from 2017 to 2019. NARE-BG registered for VAT on 25 November 2019 and submitted VAT returns with no tax payable or receivable until 30 September 2020. Due to the COVID-19 pandemic, Bulgaria extended time limits for tax declaration and payment, but not for VAT. On 14 January 2021, NARE-BG filed a VAT return for December 2020, claiming the VAT on invoices from 2017-2019, but the Bulgarian tax authorities refused the right to deduct, as the right to deduct must be exercised in the registration period or within 12 subsequent periods.

Source BTW jurisprudentie

See also

• C-429/23 (NARE-BG) – Judgment – No Right to deduct input VAT for supplies received before their registration under national law during COVID-19

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