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Check this out - I hope that I don't 'shot myself in my foot' by saying that the M1906 Portuguese Navy Contract Lugers were instead a Spainish contract ((when I happen to have an outstanding Portuguese Royal Navy rig in my collection)!! (just kidding) Using your line of thought, why not?
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Come to think of it, I recently picked up a box of 9mm para that came from Spanish storage and dated from the Spanish civil war. It was filled with ammunition made in Portugal and by DWM in Berlin.
So be careful what you wish for
Anyway, back on topic.
The key points sofar that point towards Bulgarian rather than Russian origin in my opinion are:
-The markings are Bulgarian, not Russian.
-During the contract years, Bulgaria was severing it's ties with the Ottoman (Turkish) empire.
-Early documents, including one from Hans Tauscher, of 1906, and of the Swiss KTA, of 1911 only mention Bulgarian contracts, not Russian.
-Bulgaria had enough Mosin-Nagants to validate the use of M-N rifles on the chamber.
The issues that need to be resolved are.
-The fact that DWM was not allowed to sell to Bulgaria between 1907 and 1914 as a result of a cartel agreement with Steyr.
-No historical record of these lugers in contemporary Russian and Bulgarian documents found sofar.
-No recollection by August Weiss about these contracts, which suggest that, if they took place, they took place long before WW1.
Some consolidation:
-Bulgarian archives appear to be well preserved.
-Cartel agreement between Steyr and DWM means that DWM could only deliver to Bulgaria with approval of Steyr: Hence, possible proof in Steyr / Austrian archives.
-Russian archives are well preserved as well.
The bad news:
-DWM archives used to light the stove and as improvised kleenex during crisis times.
-Most of us lack Bulgarian and Russian language capabilities.