I agree with what you say but also f.e.:
If you want to use Google Webmaster tools and there to set different Geotargeting for the two language versions:
domain.com/bg
domain.com/en
Than you have to add them in Google Webmaster Tools as two different sites, so that you can give them a Geotargeting for specific country. Which Google says “This will also improve Google’s search results for geographic queries.”
https://support.google.com/webmasters/bin/answer.py?hl=bg&answer=62399
So 2 different sitemaps will be needed to add it both sites, because you can not send Google the same sitemap with all links in both sites.