Tax in Bulgaria

Who is the tax authority and where do filings live?

Natsionalna Agentsiya za Prihodite (NAP, the National Revenue Agency), under the Ministry of Finance, administers Bulgaria's tax system through Sofia and regional directorates plus the Sofia Large Taxpayers and Insurers Office [SC1]. Customs is administered by Agentsiya Mitnitsi. Filings flow through the NAP electronic services portal. Substantive law: Personal Income Taxes Act (ZDDFL), Corporate Income Tax Act (ZKPO), VAT Act (ZDDS), Tax-Insurance Procedure Code, and the Pillar Two transposition under successive amendments. Bulgaria has been an EU member since 2007 and applies the EU VAT Directive 2006/112/EC; euro adoption took effect 1 January 2026.

What is the tax year and when are returns due?

The individual tax year is the calendar year. Personal income tax returns are due 30 April of the year following the tax year via electronic filing on the NAP portal [SC1]. Corporate fiscal years align with the calendar year (with limited exception); annual ZKPO returns are due 30 June (extended from 31 March under successive amendments). Monthly VAT returns are due by the 14th of the following month under the standard regime; quarterly is available below specified thresholds. Withholding tax returns are due monthly by the 15th. The annual financial statement and corporate annual activity report are required separately under the Accountancy Act.

Who is a Bulgarian tax resident?

Under Article 4 of the ZDDFL, an individual is tax resident in Bulgaria if (a) maintaining a permanent address in Bulgaria, OR (b) physically present in Bulgaria for more than 183 days in any 12-month period (with residence taking effect from the year in which the day count is reached), OR (c) sent abroad by the Bulgarian state or by enterprises/organisations established in Bulgaria, OR (d) maintaining their centre of vital interests in Bulgaria [SC2]. Residents are taxed on worldwide income; non-residents on Bulgarian-source income at flat rates. Treaty tie-breakers under the OECD Model framework apply for dual-residents.

What are the personal income tax rates?

Bulgaria applies a flat 10 percent personal income tax on most categories of income (employment, business, rental, capital gains) since 1 January 2008 [SC1]. Sole proprietors face 15 percent flat on business income (under Article 48 ZDDFL). Investment income (dividends from Bulgarian companies) faces 5 percent withholding (final). Capital gains on disposal of immovable property face 10 percent flat with first-residence exemption available under specific conditions; capital gains on listed-share disposals on EU/EEA regulated markets are exempt under Article 13 ZDDFL. Mandatory social security and health insurance contributions add ~13 percent employee-side. Personal allowance for low earners has been progressively introduced (BGN 600 standard for 2024, plus BGN 7,200 family-tax-credit-equivalent for one child).

How are corporations taxed?

The corporate income tax rate is a flat 10 percent on taxable profit — among the lowest headline rates in the EU [SC2]. Tonnage tax regime applies to qualifying maritime shipping companies. Withholding tax on dividends to non-residents is 5 percent (treaty rates apply; 0 percent for EU/EEA participation under the Parent-Subsidiary Directive). Pillar Two QDMTT and IIR apply for fiscal years starting on or after 31 December 2023, transposing EU Directive 2022/2523 via successive amendments to the ZKPO; the UTPR applies for fiscal years starting on or after 31 December 2024 [SC3]. The QDMTT collects top-up tax to 15 percent at the entity level for in-scope MNE groups, materially reducing the effective benefit of the 10 percent headline for affected groups. Tax loss carryforwards: 5 years; carryback unavailable.

What about VAT (DDS)?

The standard VAT (DDS) rate is 20 percent under the ZDDS [SC4]. Reduced rate of 9 percent applies on hotel accommodation, restaurant services (post-2021 reform; some categories increased to 20 percent under successive amendments), books, baby-products, and bread (added 2023). Zero-rated supplies include exports. Registration threshold is BGN 100,000 annual turnover (raised under successive amendments). Reverse-charge mechanism applies on certain domestic supplies. EU OSS/IOSS regimes apply to digital and distance-sale supplies. Mandatory e-invoicing has been progressively introduced; the SAF-T (Standard Audit File for Tax) reporting framework is being phased in.

How are cryptoassets taxed?

Bulgaria taxes individual cryptoasset disposal gains as 'other income' at the flat 10 percent personal income tax rate, with acquisition cost deductible [SC2]. NAP guidance from 2014 onward (Letter No. 24-34-50) confirms the 10-percent flat treatment with FIFO cost-basis assumption. Mining and staking income are business income at 15 percent flat (sole proprietors) or under regular corporate rules. Crypto-asset service providers operate under EU MiCA Regulation from 30 December 2024 with supervision by the Financial Supervision Commission (FSC) and Bulgarian National Bank (BNB) for stablecoin issuers. NFTs follow the same framework as fungible cryptoassets.

What is the treaty network and what are the audit triggers?

Bulgaria has approximately 70 active double tax treaties [SC5]. EU directives (Parent-Subsidiary, Interest-Royalties, ATAD I/II) apply alongside treaties. Bulgaria ratified the OECD MLI on 16 September 2022 with modifications entering force from 1 January 2023 onward depending on counterparty. Audit triggers include disproportionate VAT credits, transfer-pricing non-compliance under Article 15 ZKPO (TPD/CbCR documentation thresholds), undeclared bank deposits flagged via DAC2/CRS, and inconsistencies on the SAF-T reporting framework. Standard SOL is 5 years from the year of return filing; 10 years for fraud or non-filing.