# Company in Bulgaria (EOOD/OOD): 10% Tax, 5% Dividends and Substance

> Bulgarian EOOD and OOD: 10% corporate tax, 5% dividend tax (0% to EU/EEA companies, except hidden profit distribution), €51,130 VAT threshold, euro since 2026.

Author: Gordey Bolotko — Partner, Corporate & Commercial (https://wiki.private.law/en/authors/bolotko)
Last modified: 2026-09-23T00:00:00.000Z
Canonical: https://wiki.private.law/en/company-bulgaria
Publisher: wiki.private.law (https://wiki.private.law)
Version: d3f520ac4cd8b6e733ad24171130f5e9abfe41b29610dd98c878a065c05d723e
Cite as: Company in Bulgaria (EOOD/OOD): 10% Tax, 5% Dividends and Substance. wiki.private.law. https://wiki.private.law/en/company-bulgaria. Version d3f520ac4cd8b6e733ad24171130f5e9abfe41b29610dd98c878a065c05d723e.
Topics: structures
Jurisdictions: bulgaria, eu
Functional tags: company, substance
Product tags: company, tax-regime, substance
Semantic tags: company, substance, tax-regime

---

## Concept

A Bulgarian limited liability company — an **OOD**, or an **EOOD** where there is a single member — is a euro-area corporate vehicle with one of the simplest tax set-ups in the EU. Profits are taxed at 10%, dividends bear 5% withholding tax, and no withholding applies when the dividend goes to a company resident in the EU or EEA. Bulgaria adopted the euro on 1 January 2026 at the [fixed rate of 1.95583 leva](https://eur-lex.europa.eu/eli/reg/2025/1409/oj), so the company's capital, accounts and reporting are now in euro.

Demand for the vehicle rests on three things. The first is arithmetic: out of 100 of profit, an individual owner keeps 85.5 after Bulgarian corporate tax and dividend tax, a combined Bulgarian burden of 14.5%. That is the owner's final figure only where the owner is resident in Bulgaria or in a state that does not tax the dividend again; the state where the owner lives may add its own tax, with credit for the Bulgarian 5% only as far as its rules or a tax treaty allow. The second is EU membership: a Bulgarian company can register for an EU VAT number and has access to the EU dividend directives and to euro payment infrastructure. The third is a low entry threshold: after the euro changeover the minimum capital of an OOD is €1.

The weakness sits in the same design. Bulgaria treats the company as a tax resident because it is registered there and does not ask where it is managed from. The state where the owner lives asks exactly that. The 10% therefore holds when management and business are genuinely in Bulgaria, and stops holding when all that Sofia has is an address.

Key parameters in 2026:

| Parameter | Value |
| --- | --- |
| Corporate income tax | 10%, flat rate |
| Dividends to individuals (resident and non-resident) | 5%, final tax |
| Dividends to companies outside the EU/EEA | 5% withholding |
| Dividends to EU/EEA companies | 0%, except hidden profit distribution |
| VAT and registration threshold | 20%; €51,130 of turnover per calendar year |
| Minimum capital, OOD / AD | €1 / €25,000 |
| Currency | euro since 1 January 2026 |

The table shows that there are essentially two rates — 10% and 5% — with almost no reliefs or special regimes; the final burden is decided by the place of management and by who the owners are.

## How it works: from registration to dividend

The life cycle of a Bulgarian company is short. The founder signs the memorandum (for an EOOD) or the articles (for an OOD), pays in the capital, since at least the statutory minimum must be paid before registration ([Art. 119(1) of the Commerce Act](https://www.mi.government.bg/file/2011/08/targovski_zakon_31.07.2026.pdf)), and files an application with the Commercial Register kept by the Registry Agency. Beneficial ownership details are entered in the register at the same time. Once registered, the company opens a current account, registers for VAT where required and starts trading.

Annual profit is taxed at 10%, and the annual return is filed with the National Revenue Agency (NRA). The sole owner or the general meeting decides on a dividend, and on payment the company withholds tax at source.

```mermaid
flowchart TD
    F["Founder"] -->|"capital from €1"| E["EOOD in Bulgaria"]
    E -->|"10% on profit"| N["NRA"]
    E -->|"dividend: 5% withheld"| F
    E -->|"dividend: 0%"| P["EU/EEA company"]
```

The diagram shows two levels of tax and a fork at the payment stage. An individual or a non-EU company receives the dividend net of 5%. A parent company from the EU or EEA receives it without withholding, and what happens next depends on the rules of its own state. How such a chain is built is covered in [the holding ladder and dividend flows](https://wiki.private.law/en/holding-dividend-flows).

## Forms: EOOD, OOD and AD

The [Commerce Act](https://www.mi.government.bg/file/2011/08/targovski_zakon_31.07.2026.pdf) recognises several forms, but three matter in practice for private capital. They differ in the number of members, the minimum capital (Arts 117 and 161) and whether capital is divided into shares of interest or into stock.

| Form | Members | Minimum capital | Typical use |
| --- | --- | --- | --- |
| EOOD | one (individual or company) | €1 | founder's operating company, group subsidiary, holding land |
| OOD | two or more | €1 | joint business, venture stakes |
| AD | one or more shareholders | €25,000 | company with share capital, public offering |

The EOOD and the OOD are one legal form with a different number of members; in both, a member's liability is limited to the contribution. The company is run by a manager (upravitel) appointed by the owner. Where the manager actually takes decisions determines where the company ends up tax resident.

Capital of €1 is a corporate minimum and has nothing to do with regulatory capital. Licensed activities set their own requirements, and those are orders of magnitude higher; how such a figure is assembled from an initial minimum, an ongoing formula and deductions is covered in [regulatory capital](https://wiki.private.law/en/regulatory-capital).

## Tax mechanics

### Corporate income tax at 10%

Corporate income tax is 10%, with no progression ([Art. 20 of the Corporate Income Tax Act](https://nra.bg/wps/wcm/connect/nra.bg25863/ed10ff12-b25a-4b07-827c-915979acef42/%D0%97%D0%9A%D0%9F%D0%9E.pdf?MOD=AJPERES)). A Bulgarian company is taxed on its worldwide profit. Dividends received from Bulgarian companies and from companies tax-resident in the EU or EEA are not included in taxable profit, whatever the size of the holding. The exemption does not apply to hidden profit distribution, to amounts the paying company deducted as an expense, or to dividends from REITs and securitisation companies (Art. 27 of the Corporate Income Tax Act).

Gains on the sale of shares and interests are taxed at the standard 10%. They are excluded only when the disposal itself is executed on a regulated market or, from 2026, an SME growth market in the EU or EEA, on an equivalent third-country market recognised by the European Commission, or through a tender offer (Art. 44 and § 1, item 21 of the Supplementary Provisions of the same Act). A private sale of an EOOD's interest, or an off-market sale of listed shares, is taxed at 10%.

This is the limit for a holding: the exemption covers only dividends from the EU and EEA. Dividends from subsidiaries in third countries are included in taxable profit and taxed at 10%, so Bulgaria serves as a holding for European subsidiaries and falls behind the classic holding jurisdictions reviewed in [holding structures](https://wiki.private.law/en/holding-structures).

> 🧭 **Where Bulgaria sits in the line-up.** It is absent from the holding matrix in [holding structures](https://wiki.private.law/en/holding-structures) and from the navigation table of the [companies hub](https://wiki.private.law/en/companies-hub), and the reason is the boundary of the participation exemption: it stops at the EU and the EEA. Bulgaria is therefore chosen as an operating company inside the single market, not as the top tier of a group holding third-country subsidiaries. It is equally outside the zero-tax perimeter compared in [offshore companies](https://wiki.private.law/en/offshore-companies) — the 10% is paid, filed and creditable. Moving an existing company into the form, rather than incorporating a new one, follows the routes in [redomiciliation](https://wiki.private.law/en/redomiciliation-routes).

### Dividends: 5%, 0% and the 2026 budget

Dividend tax arises on payment and is withheld by the company.

| Recipient | Rate | Basis |
| --- | --- | --- |
| Individual, resident or non-resident in Bulgaria | 5% | final tax under Art. 46(3) of the [Personal Income Tax Act](https://nra.bg/wps/portal/nra/zakonodatelstvo/zakonodatelstvo_priority/da0cc1aa-c4b2-4863-b1de-5f2f94d9f2d6) |
| Company outside the EU/EEA | 5% | Arts 194 and 200(1) of the [Corporate Income Tax Act](https://nra.bg/wps/wcm/connect/nra.bg25863/ed10ff12-b25a-4b07-827c-915979acef42/%D0%97%D0%9A%D0%9F%D0%9E.pdf?MOD=AJPERES) |
| Company tax-resident in the EU/EEA | 0% | exemption under Art. 194(3); not for hidden profit distribution |

A tax treaty matters only where its rate is below the domestic 5%. The general logic of withholding is covered in [withholding tax](https://wiki.private.law/en/withholding-tax).

The draft 2026 budget proposed doubling dividend tax from 5% to 10%. The draft was withdrawn after mass protests in December 2025, and the cabinet resigned. Parliament adopted the 2026 State Budget Act on 24 July 2026 ([State Gazette No. 69 of 31.07.2026](https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=245041)); it did not amend dividend tax, and the rate remains 5% under Art. 46(3) of the Personal Income Tax Act and Art. 200(1) of the Corporate Income Tax Act.

### VAT: the €51,130 threshold

From 1 January 2026 the registration threshold is measured over a calendar year instead of a rolling twelve months, and Bulgaria introduced the EU special scheme for small enterprises at the same time. The main parameters of the [VAT Act](https://www.damtn.government.bg/wp-content/uploads/zakoni/zakon-za-danak-varhu-dobavenata-stoinost.pdf):

| Parameter | Value |
| --- | --- |
| Standard rate (Art. 66) | 20% |
| Reduced rate (Art. 66a) | 9%: hotel accommodation, books and periodicals, baby food and baby hygiene products |
| Mandatory registration (Art. 96(1)) | €51,130 of taxable turnover in a calendar year |
| Application deadline (Art. 96(6)) | 7 days after the threshold is exceeded |
| EU SME scheme ceiling (Art. 96(2)) | €100,000 of EU-wide turnover |

Within that ceiling the scheme of [Directive 2020/285](https://eur-lex.europa.eu/eli/dir/2020/285/oj) lets a company use the small-business exemption in other EU states as well, where its turnover there is below the national threshold.

### Pillar Two and CFC

The 15% global minimum tax applies to groups with consolidated revenue of €750 million or more ([Art. 2 of Directive 2022/2523](https://eur-lex.europa.eu/eli/dir/2022/2523/oj)). Bulgaria applies the income inclusion rule (IIR) and a qualified domestic minimum top-up tax (QDMTT) from 2024, and the undertaxed profits rule (UTPR) from 2025. These rules do not reach a founder's company with lower revenue. A Bulgarian subsidiary of an in-scope group may owe a top-up tax that brings the group's effective rate in Bulgaria, on profit above the substance-based income exclusion, up to 15%. The mechanics are covered in [Pillar Two](https://wiki.private.law/en/pillar-two).

Controlled foreign company (CFC) rules operate in the owner's country. The [ATAD](https://eur-lex.europa.eu/eli/dir/2016/1164/oj) requires every EU state to apply them to corporate taxpayers (Art. 1), so the profit of a Bulgarian subsidiary taxed at 10% can be included in the tax base of an EU parent. The inclusion does not reach a subsidiary that carries on a substantive economic activity supported by staff, equipment, assets and premises (Art. 7(2)(a)), and the alternative test of Art. 7(2)(b) catches only non-genuine arrangements. Individual owners face only the national CFC rules of their own state, where it has them — see [ATAD I CFC](https://wiki.private.law/en/eu-atad-cfc).

## Tax residence and place of management

Two different tests meet over the same company, one in Bulgaria and one in the state from which it is run.

**Bulgaria: incorporation test**

A company incorporated under Bulgarian law and entered in a Bulgarian register is a local legal person ([Art. 3 of the Corporate Income Tax Act](https://nra.bg/wps/wcm/connect/nra.bg25863/ed10ff12-b25a-4b07-827c-915979acef42/%D0%97%D0%9A%D0%9F%D0%9E.pdf?MOD=AJPERES)). Place of management plays no part, so under Bulgarian domestic law the company is taxed in Bulgaria whoever runs it.

**Owner's state: place of management**

Many states treat a foreign company as resident where its executive body regularly acts or its senior officers predominantly manage it, unless a tax treaty provides otherwise. Under the names effective management or central management and control, the test catches a company whose manager works from abroad.

The result is dual residence: Bulgaria taxes the company as its own, and so does the owner's country. A tax treaty between the two states can break the tie and allocate residence to one of them, typically the state where effective management is located; Bulgaria's domestic rule then gives way to the treaty. How such conflicts are resolved, and why the place where decisions are taken is decisive, is covered in [corporate tax residence](https://wiki.private.law/en/corporate-tax-residence) and [the tie-breaker](https://wiki.private.law/en/tax-residency-tiebreaker).

> 🍓 The two tests decide together whether the 10% is final. A company run from Sofia by people who live there keeps the combined 14.5% on distributed profit; a company registered in Sofia and run from elsewhere pays the Bulgarian 10% and stays exposed to the other state's tax on the same profit. Even then, 14.5% is the owner's whole burden only when the owner is resident in Bulgaria or in a state that does not tax the dividend again.

## Substance, bank and the euro

### What counts as presence

The 10% rate in Bulgaria does not depend on presence: every registered company pays it. Substance is tested by others, and each of the three testers asks its own question.

**Owner's tax authority**

Settles place of management and applies its CFC rules: where decisions are taken and whether the profit stays with the company.

**Parent company's state**

Applies the anti-abuse clauses of the EU directives before it exempts a dividend from the Bulgarian subsidiary.

**The bank**

Establishes whose business it is, where the money comes from and whether the activity is real.

A robust set-up looks the same to all three: the manager lives and works in Bulgaria, and the company has an office, staff and local counterparties. The general logic is in [economic substance](https://wiki.private.law/en/economic-substance).

### Bank account after the euro changeover

From 1 January 2026 lev balances and obligations were converted at 1.95583, and settlement runs in euro. Capital in the constitutional documents must be redenominated: according to the [Registry Agency](https://portal.registryagency.bg/page/161), limited liability companies must file updated articles within 12 months of the date the euro was introduced, together with their next application to the register.

The euro changeover did not change onboarding. The bank looks at the owners, the source of funds and whether the business is real, and for founders from outside the EU the review is usually more detailed. Which banks operate in Bulgaria and how they open accounts for companies and non-residents is covered in [banks in Bulgaria](https://wiki.private.law/en/bulgaria-banks).

### Beneficial ownership register

Beneficial owners — individuals who directly or indirectly hold 25% or more of the shares or votes, or otherwise exercise control — are entered in the Commercial Register under Art. 63 of the [Measures Against Money Laundering Act](https://eur-lex.europa.eu/legal-content/BG/TXT/PDF/?uri=NIM%3A202503553). Entries and changes are filed within seven days (Art. 6(2) of the [Commercial Register and Register of Non-Profit Legal Entities Act](https://www.registryagency.bg/media/filer_public/2026/01/08/zakon_za_trgovskiia_registr_i_registra_na_iuridicheskite_litsa_s_nestopanska_tsel_6hVKxkJ.pdf)). How public access to such registers changed after the 2022 ruling of the EU Court of Justice is covered in [UBO registers](https://wiki.private.law/en/ubo-registers); the rest of that Act, which binds banks and licensed firms, is set out in [AML in Bulgaria](https://wiki.private.law/en/bulgaria-aml-framework).

## Owners from outside the EU

### Deposits and services under Regulation 833/2014

EU sanctions against Russia show most sharply how the owner's origin, rather than the company's, changes what EU providers may do. [Art. 5b(1) of Regulation 833/2014](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20260724) prohibits credit institutions from accepting deposits above €100,000 per institution from the persons in the first column; Art. 5b(3) lifts the prohibition for those in the second.

**Caught by Art. 5b(1)**

Russian nationals and natural persons residing in Russia; legal persons established in Russia; legal persons established outside the EU and more than 50% owned by Russian nationals or residents.

**Outside the limit**

Nationals of an EU or EEA state or of Switzerland, and holders of a temporary or permanent residence permit there (Art. 5b(3)). A Bulgarian company itself, which is established inside the EU, is outside the wording whoever owns it. The Commission, however, reads Art. 5b together with the anti-circumvention rule of Art. 12 and expects banks to apply enhanced due diligence to deposits of such a company when it is owned by Russian nationals or residents of Russia ([FAQ on deposits, Q27 and Q36](https://finance.ec.europa.eu/document/download/a2f66733-09b6-43ec-b8f5-c594a55ca997_en?filename=faqs-sanctions-russia-deposits_en.pdf)).

Art. 5b(2) separately prohibits providing Russian nationals, residents of Russia and entities established there with crypto-asset services, the issuing of payment instruments, acquiring, payment initiation and the issuing of electronic money, and the Art. 5b(3) exemption applies to it too. An owner with neither EU, EEA or Swiss nationality nor such a residence permit therefore meets the deposit cap on personal accounts and cannot be issued a card or e-money by an EU provider, whatever the balance.

[Art. 5n](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20260724) of the same regulation prohibits supplying accounting, auditing, bookkeeping, tax consulting, business and management consulting and a further list of professional services to legal persons established in Russia. An EU company with a shareholder in a restricted jurisdiction is not caught by that wording on its own; it is caught where the service is in substance rendered for the benefit of a parent established there, so a Bulgarian accountant who serves the EOOD may not also serve its Russian parent company. The perimeter is mapped in the [sanctions route map](https://wiki.private.law/en/sanctions-map).

### What the 10% does not settle

The rate answers for Bulgaria alone. Whether it is the owner's final rate is decided in the owner's own state by two mechanisms: the place-of-management test described above, and a CFC regime that compares the foreign effective rate with the domestic one and attributes the profit to the controlling person when it falls short. A tax treaty that has been suspended or terminated removes the relief machinery without removing the Bulgarian withholding, so the 5% at source is still paid and may have nothing to be credited against. The treaty with Russia is the current case: by [Decree No. 585 of 8 August 2023](http://publication.pravo.gov.ru/document/0001202308080005) Russia suspended Articles 5–22 and 24 of the 1993 treaty, including the dividend article.

Banks apply their own filter above the legal one. Accounts are opened after a review of the owners and of the origin of the money, described in [source of funds](https://wiki.private.law/en/source-of-funds). A Bulgarian registration settles where the company sits; it does not oblige any bank to take it.

## The company as a base for a licence or an asset

A Bulgarian company is the corporate base for licensed business — [payments and e-money](https://wiki.private.law/en/bulgaria-emi-license), crypto-assets or [investment services](https://wiki.private.law/en/bulgaria-investment-firm). The corporate form is the same EOOD or AD; what changes with the regime is the supervising authority, the permitted activity and the capital. Which regime corresponds to which activity across the EU is set out in the [financial licences map](https://wiki.private.law/en/fintech-license-map), the Bulgarian regimes and their two regulators in [financial licences in Bulgaria](https://wiki.private.law/en/bulgaria-financial-licenses), and the arithmetic behind each capital figure in [regulatory capital](https://wiki.private.law/en/regulatory-capital). A licence also reverses the logic of the €1 minimum: capital stops being a formality and becomes a continuing prudential obligation. For a crypto-asset business EU sanctions also limit who may stand behind the company: Art. 5b(2a) of Regulation 833/2014 bars Russian nationals and residents of Russia without the Art. 5b(3) status from owning, controlling or sitting on the governing bodies of an EU company providing crypto-asset services — wallet, account and custody services since 18 January 2024, and any MiCA crypto-asset service since 25 August 2026. The Bulgarian licence itself is described in [the CASP licence in Bulgaria](https://wiki.private.law/en/bulgaria-casp-license).

The second common scenario is an EOOD for buying land. Foreigners and foreign legal persons acquire land in Bulgaria only on the terms of Bulgaria's EU accession or of a ratified treaty, or by inheritance ([Art. 22(1) of the Constitution](https://www.parliament.bg/bg/const)), so an owner from outside the EU and EEA usually buys through a Bulgarian company. The route stops at agricultural land: companies whose members or shareholders are foreign persons from outside the EU and EEA (absent a ratified treaty), companies with direct or indirect shareholders registered in preferential tax jurisdictions, and joint-stock companies with bearer shares may neither acquire nor hold it ([Art. 3(7) of the Agricultural Land Ownership and Use Act](https://www.mzh.government.bg/bg/normativni-aktove/zakoni/)). Property purchase is covered in [buying property in Bulgaria](https://wiki.private.law/en/bulgaria-property-purchase).

## Running and closing the company

A Bulgarian company carries two annual filings, one to the tax authority and one to the Commercial Register, and a dormant company still has to declare that it did not trade.

| Obligation | Deadline | Basis |
| --- | --- | --- |
| Annual corporate tax return, with the annual activity report | 1 March – 30 June of the following year | [Art. 92(2)–(3) CITA](https://nra.bg/wps/wcm/connect/nra.bg25863/ed10ff12-b25a-4b07-827c-915979acef42/%D0%97%D0%9A%D0%9F%D0%9E.pdf?MOD=AJPERES) |
| Annual financial statements, published through the Commercial Register | by 30 September of the following year | [Art. 38(1)(1) of the Accountancy Act](https://www.registryagency.bg/media/filer_public/2026/01/08/zakon_za_schetovodstvoto.pdf) |
| Year without activity | no tax return; a one-off declaration published in the Commercial Register by 30 June | Art. 92(4) CITA; Art. 38(9)(2) of the Accountancy Act |
| Change of beneficial owners | within 7 days | Art. 6(2) of the Commercial Register Act |

The filings follow the company for as long as it exists, so closing it is a procedure of its own. A decision of the members to dissolve an OOD or EOOD opens a liquidation, and the manager acts as liquidator unless the articles or the members appoint someone else (Art. 156 of the Commerce Act). The liquidator invites the creditors, and the invitation is announced in the Commercial Register (Art. 267). The remaining assets may be distributed only six months after that announcement (Art. 272(1)), and once all debts are settled the liquidator applies for deletion from the register (Art. 273(1)). What the owner receives is a liquidation share, taxed like a dividend: 5% for an individual or a company outside the EU and EEA, 0% for an EU or EEA company (Arts 194 and 200(1) CITA; Art. 46(3) of the Personal Income Tax Act for individuals).

## Letterbox company: where the model fails

> ⚠️ **A "letterbox" in Sofia for the 10%.** The company is registered at a service provider's address, the manager and owner live in another country, and decisions are taken there. Bulgaria collects its 10%, while the owner's country treats the company as its own resident by place of management or taxes its profit in the owner's hands under CFC rules. The result is tax twice, and a bank that finds no business behind the company may close the account.

The arrangement lasts only until the first review in the owner's country. For 10% to become the final rate, management moves to Bulgaria: the manager, the decisions, the people and the contracts.

## Q/A

### Tax

### How much tax does a Bulgarian company pay if it distributes all its profit?

10% corporate tax on profit and 5% on dividends paid to an individual or a non-EU company. Out of 100 of profit an individual keeps 85.5 at the Bulgarian level; an owner resident in another state may be taxed on the dividend there as well. No withholding applies on a payment to a parent company from the EU or EEA, unless the payment is a hidden profit distribution.

### Did dividend tax rise to 10% in 2026?

No. The increase from 5% to 10% was in the first draft of the 2026 budget, but the draft was withdrawn in December 2025. The budget adopted on 24 July 2026 did not change the rate, which remains 5%.

### Does Bulgaria work as a holding location?

For subsidiaries in the EU and EEA, yes: dividends received from them are exempt whatever the size of the holding, unless they are a hidden profit distribution or were deducted by the payer. Dividends from third countries are taxed at 10%, so a global holding is usually placed elsewhere.

### Registration, management and banking

### Does it matter where the manager lives?

For Bulgaria, no: the company remains Bulgarian resident because it is registered there. For the country from which the manager runs the company, yes: under a place-of-management test it may treat the company as its own resident, which produces dual residence. A tax treaty between the two states may then allocate residence to one of them, usually by the place of effective management.

### What happens to capital stated in leva after the euro changeover?

It is redenominated into euro at the fixed rate of 1.95583: limited liability companies file updated articles with capital in euro with the Commercial Register within 12 months of the euro's introduction, together with their next application for entry.

### Who goes into the beneficial ownership register?

Individuals who directly or indirectly hold 25% or more of the shares or votes, or otherwise exercise control over the company. The data are entered in the Commercial Register, and entries and changes are filed within seven days.

### What does a Bulgarian company file every year?

An annual corporate tax return between 1 March and 30 June and its annual financial statements, published through the Commercial Register by 30 September of the following year. A company that did not trade files no tax return but publishes a one-off declaration of inactivity by 30 June.

### Owners from outside the EU

### Does the €100,000 deposit limit restrict the account of a Bulgarian company?

The company is established in the EU and does not fall within the wording on entities outside the EU, although under the anti-circumvention rule of Art. 12 the Commission expects banks to apply enhanced due diligence to deposits of an EU company owned by Russian nationals or residents. The limit applies to personal deposits of Russian nationals and of natural persons residing in Russia, and not to those who also hold the nationality of an EU or EEA state or of Switzerland, or a residence permit in one of them. The same exemption governs Art. 5b(2), which bars EU providers from issuing payment cards and e-money to such persons. A bank may still decline under its own risk policy.

### Does paying 10% in Bulgaria close the tax question for the owner?

For Bulgaria, yes. The owner's state then applies its own place-of-management and CFC tests. In the ATAD version of the CFC test the subsidiary's profit is attributed to the controlling company where the tax actually paid abroad is lower than the difference between the tax the owner's state would have charged on that profit and the tax actually paid, so a 10% rate brings the question into scope rather than closing it.

### Can an owner from outside the EU buy land through a Bulgarian company?

Non-agricultural land, yes: the company is a Bulgarian legal person. Agricultural land, no: a company whose members or shareholders are foreign persons from outside the EU and EEA, absent a ratified treaty, may neither acquire nor hold it (Art. 3(7) of the Agricultural Land Ownership and Use Act).

---

## Factual claims

- Key parameters in 2026:
- The table shows that there are essentially two rates — 10% and 5% — with almost no reliefs or special regimes; the final burden is decided by the place of management and by who the owners are.
- Annual profit is taxed at 10%, and the annual return is filed with the National Revenue Agency (NRA).
- Capital of €1 is a corporate minimum and has nothing to do with regulatory capital.
- Corporate income tax is 10%, with no progression (Art. 20 of the Corporate Income Tax Act).
- Gains on the sale of shares and interests are taxed at the standard 10%.
- A tax treaty matters only where its rate is below the domestic 5%.
- The draft 2026 budget proposed doubling dividend tax from 5% to 10%.

---

Source: wiki.private.law — the private.law legal knowledge base. When quoting, cite the canonical page URL.
Consultation with a lawyer: https://t.me/private_law_bot