Corporate Income Tax in Bulgaria in 2026: The Complete Guide for Foreign Business Owners
The 10% Rate, Taxable Profit Calculation, Deductible Expenses, International Income, Advance Payments, the Global Minimum Tax, and Why Bulgaria Remains the EU’s Most Competitive Corporate Tax Jurisdiction
10% corporate income tax rate
Flat no progressive bands
0% municipal surcharge
30 June annual return deadline
Introduction
Bulgaria has maintained a 10% flat corporate income tax rate for nearly two decades. It is the lowest corporate tax rate in the European Union — tied only with Hungary’s 9% headline rate, which applies subject to conditions that do not affect most businesses. For the vast majority of companies operating in Bulgaria, 10% is the rate, and it applies equally to domestic and foreign-owned entities, to all sectors, and to all income types from standard commercial activity.
In 2026, the context around Bulgarian corporate tax has strengthened further. Full Schengen membership, adopted in 2024, eliminated border friction for goods and services. Euro adoption in January 2026 completed Bulgaria’s integration into the EU’s monetary architecture, making Bulgarian-company invoices directly denominated in the EU’s common currency and eliminating BGN/EUR exchange risk. The global minimum tax (Pillar Two, 15%) has entered into force across the EU, but applies only to groups with consolidated revenue above €750 million — a threshold that excludes the overwhelming majority of the international SMEs and entrepreneurs who register Bulgarian companies.
This guide explains everything a foreign business owner needs to know about Bulgarian corporate income tax in 2026: who is subject to it, what profit is taxable, which expenses reduce the tax base, how the advance payment system works, how international income is treated, what the global minimum tax means and who it affects, and how Bulgaria compares to its EU competitors on a combined corporate-and-dividend basis.
What Is Bulgarian Corporate Income Tax?
The Legal Framework
Bulgarian corporate income tax (CIT) is governed by the Corporate Income Tax Act (Закон за корпоративното подоходно облагане — ЗКПО). It is levied on the net taxable profit of Bulgarian-resident companies and on certain income earned in Bulgaria by non-resident companies.
The taxable profit is calculated as the accounting profit (the difference between revenues and expenses in the company’s financial statements) adjusted for specific items prescribed by the ZKPO: certain non-deductible expenses are added back to profit, and certain tax deductions or preferences reduce the base. For most small and medium-sized businesses, the tax adjustments are minimal and the taxable profit closely approximates the accounting profit.
The Key Characteristics of Bulgarian CIT
| Characteristic | Detail |
|---|---|
| Rate | 10% flat — no progressive bands; the same rate applies whether profit is €1,000 or €10,000,000 |
| Tax base | Net taxable profit: revenue minus deductible expenses, adjusted for ZKPO-specific items |
| Municipal surcharge | None — Bulgaria does not impose a municipal or local corporate tax surcharge on top of the national 10%; the 10% is the total corporate tax |
| Minimum alternative tax | Small alternative tax (altenrativen danuk) of 5% on revenue applies only to certain unprofitable companies in specific circumstances; does not affect profitable businesses |
| Territorial scope | Bulgarian-resident companies are taxed on worldwide profit; non-residents only on Bulgarian-source income through a permanent establishment |
| Tax year | Calendar year (1 January – 31 December) |
| Annual return deadline | 30 June of the year following the tax year |
| Final payment deadline | 30 June of the year following the tax year (coincides with return filing) |
| Advance payment system | Mandatory for companies meeting certain revenue thresholds; monthly or quarterly instalments during the tax year |
Who Pays Bulgarian Corporate Income Tax?
Bulgarian-Resident Companies — Worldwide Profit
A company is a Bulgarian tax resident if it is incorporated and registered in Bulgaria — that is, if it is registered in the Bulgarian Commercial Register (Търговски регистър). This includes all OODs (multi-owner limited liability companies), EEODs (single-owner limited liability companies), ADs (joint stock companies), and other Bulgarian legal entities.
A Bulgarian-resident company is taxed on its worldwide profit: all income, from any source, anywhere in the world, is included in the Bulgarian taxable profit. A Bulgarian EOOD owned by a German entrepreneur that provides consulting services to clients in Germany, France, and the United States pays Bulgarian CIT at 10% on the entire profit from all those activities — not just on income sourced in Bulgaria.
This is a critical point for international business owners: the 10% rate applies to all the company’s income globally. There is no higher rate for foreign-source income, no separate international business tax, and no exemption for income from outside Bulgaria.
Foreign Companies — Bulgarian-Source Income Only
A non-resident company (a company incorporated outside Bulgaria) is subject to Bulgarian corporate income tax only on:
- income derived through a permanent establishment (постоянно място на стопанска дейност) in Bulgaria — typically a branch, office, or agent with authority to conclude contracts in Bulgaria;
- certain categories of income arising from Bulgarian sources that are subject to withholding tax at source: dividends (5% or 10%), interest (10%), royalties (10%), management fees (10%), and certain other payments to non-residents.
How Taxable Profit Is Calculated
From Accounting Profit to Tax Liability
The calculation of Bulgarian corporate income tax follows a straightforward sequence: start with accounting profit (revenues minus costs as shown in the financial statements), apply tax adjustments required by the ZKPO, arrive at taxable profit, apply the 10% rate.
| Step | Calculation |
|---|---|
| Total revenue (turnover) for the year | €300,000 |
| Less: all deductible business expenses | − €180,000 |
| Accounting profit (per financial statements) | €120,000 |
| Add back: non-deductible expenses (per ZKPO) | + €5,000 (example) |
| Less: tax deductions / preferences (if applicable) | − €0 (most SMEs) |
| Net taxable profit | €125,000 |
| Corporate income tax @ 10% | − €12,500 |
| Net profit after tax (available for retention or distribution) | €112,500 |
| Effective CIT rate on total revenue | 4.2% |
Deductible Expenses — What Reduces the Tax Base
The General Principle
Bulgarian tax law follows the general principle that expenses are deductible if they are: documented with a proper invoice or other tax document; connected to the company’s economic activity; and not specifically excluded by the ZKPO. This is a broad and generally permissive standard that allows most genuine business costs to be deducted.
Commonly Deductible Expenses
| Expense Category | Examples | Key Documentation Requirement |
|---|---|---|
| Staff costs | Salaries, bonuses, employer’s social contributions, health insurance | Employment contracts, payroll records, payment documentation |
| Office and premises | Rent, utilities, maintenance, cleaning | Lease agreement, utility invoices, service contracts |
| Professional services | Accounting, legal, consulting, auditing, IT support | Service contracts, invoices, deliverables documentation |
| Technology and software | Software licences (SaaS), cloud services, IT infrastructure, website costs | Licence agreements, invoices, evidence of use in business |
| Marketing and advertising | Digital advertising, SEO, PR, events, printed materials, website | Campaign documentation, invoices, evidence of business purpose |
| Business travel | Flights, accommodation, conference fees, client entertainment (subject to limits) | Travel documents, hotel invoices, boarding passes; entertainment subject to per-diem and documentation rules |
| Equipment and assets | Computers, servers, office equipment; depreciated over useful life per Bulgarian accounting standards | Purchase invoices; asset register; depreciation schedule |
| Financing costs | Interest on business loans, bank charges | Loan agreements, bank statements; thin capitalisation rules apply for related-party loans |
| Insurance | Business insurance, professional liability, property insurance | Insurance policies, premium invoices |
| Depreciation | Depreciation of tangible and intangible fixed assets | Asset register; Bulgarian depreciation rates apply (not accounting rates) |
Non-Deductible Expenses — What Cannot Reduce the Tax Base
The ZKPO specifies certain expenses that are either fully or partially non-deductible, regardless of whether they appear in the company’s accounting records:
| Non-Deductible Item | Reason / Rule |
|---|---|
| Fines, penalties, and interest on overdue taxes | Public policy: companies cannot reduce tax by expensing tax penalties |
| Dividends paid (including interim distributions) | Dividends are a profit distribution, not an expense; they come from after-tax profit |
| Personal expenses of the owner disguised as company expenses | ZKPO disallows expenses not connected to business activity; personal costs are not deductible |
| Entertainment expenses above statutory limits | Partial deductibility: entertainment expenses above 1% of revenue are non-deductible |
| Donations above statutory limits | Donations are deductible up to defined thresholds; amounts above are non-deductible |
| Related-party expenses above arm’s length price | Transfer pricing rules apply; expenses to related parties must be at market rates |
| Hidden profit distributions | Payments to shareholders or related parties that disguise profit distribution rather than genuine business expense |
International Income and the 10% Rate
Bulgaria’s Treatment of Foreign-Source Revenue
One of the most practically important aspects of Bulgarian corporate taxation for international business owners is the treatment of income from outside Bulgaria. The position is clear and uncomplicated: a Bulgarian-resident company pays 10% CIT on all its profits, regardless of where the income was earned.
There is no separate rate, no additional tax, and no surcharge for international income. A Bulgarian EOOD that earns all its revenue from clients in Germany, the United Kingdom, Israel, or the United States pays 10% on the net profit from those activities — the same rate as a Bulgarian company serving only Bulgarian clients.
| Business Type | Revenue Source | Bulgarian CIT Rate |
|---|---|---|
| IT consulting company | Clients in Germany, France, and the UK | 10% on net profit |
| SaaS product | Subscribers in 50 countries worldwide | 10% on net profit |
| E-commerce store | Sales to EU customers | 10% on net profit (VAT applies separately) |
| Digital marketing agency | Clients in the US, UAE, and Israel | 10% on net profit |
| Remote developer billed through EOOD | Single client in the Netherlands | 10% on net profit |
| Holding company receiving dividends from EU subsidiaries | Dividend income from EU subsidiaries | EU Parent-Subsidiary Directive may exempt incoming dividends; 10% on other income |
| Royalty income from IP licensed internationally | Royalties from licensees in multiple countries | 10% on net royalty income; foreign withholding taxes credited under DTT |
Foreign Withholding Taxes and Double Taxation Relief
When a Bulgarian company earns income from another country and that country withholds tax at source (for example, a 5% withholding on royalties paid from Germany to Bulgaria under the Bulgaria-Germany DTT), the Bulgarian company can claim credit for the foreign withholding tax against its Bulgarian CIT liability. This prevents the same income from being taxed twice.
The credit mechanism is straightforward: the Bulgarian CIT liability on the relevant income is calculated at 10%; the foreign withholding tax already paid is deducted from this liability. If the foreign withholding exceeds the Bulgarian rate (which is uncommon given the 10% Bulgarian rate, but possible if the treaty rate is higher), the excess is not refunded but may be carried forward in some circumstances.
Advance Tax Payments — The Monthly and Quarterly System
Who Must Make Advance Payments
Bulgarian corporate income tax operates on an advance payment system for companies above certain revenue thresholds. Rather than paying the full annual tax liability in a single payment at the end of the year, qualifying companies make instalments during the year. The advance payments are then reconciled against the actual annual liability when the return is filed.
| Company Category | Advance Payment Obligation | Basis for Calculation | Payment Schedule |
|---|---|---|---|
| New companies (first year) | No advance payment obligation in the year of incorporation | No prior-year base available | Annual payment only at 30 June deadline |
| Companies with prior-year revenue below BGN 300,000 (~€150,000) | No mandatory advance payments | Below threshold | Annual payment at 30 June deadline |
| Companies with prior-year revenue BGN 300,000 to BGN 3,000,000 (~€150,000 to ~€1.5 million) | Quarterly advance payments | Based on prior-year taxable profit divided by 4, adjusted by a correction coefficient | Q1: by 15 April; Q2: by 15 July; Q3: by 15 October; Q4: by 15 December |
| Companies with prior-year revenue above BGN 3,000,000 (~€1.5 million) | Monthly advance payments | Based on prior-year taxable profit divided by 12, adjusted by a correction coefficient | By the 15th of each month for the current month |
Interest on Underpaid Advance Payments
If the total advance payments made during the year are less than 75% of the actual annual tax liability, interest is charged on the shortfall. The interest rate is the Bulgarian National Bank’s base rate plus 10 percentage points. For most small and medium businesses below the quarterly threshold, this is not relevant — they have no advance payment obligation and pay the full liability by 30 June.
Key Deadlines for Bulgarian Corporate Tax
| Obligation | Deadline | Notes |
|---|---|---|
| Annual corporate income tax return (GDK) | 30 June of the following year | Filed electronically via the NRA portal; signed with a qualified electronic certificate |
| Final annual CIT payment | 30 June of the following year | Coincides with return filing; if advance payments exceed actual liability, the overpayment is refunded |
| Quarterly advance payment (Q1) | 15 April of the current year | Applies only to companies above the quarterly threshold |
| Quarterly advance payment (Q2) | 15 July of the current year | Applies only to companies above the quarterly threshold |
| Quarterly advance payment (Q3) | 15 October of the current year | Applies only to companies above the quarterly threshold |
| Quarterly advance payment (Q4) | 15 December of the current year | Applies only to companies above the quarterly threshold |
| Monthly advance payments | 15th of each current month | Applies only to companies above the monthly threshold |
| Annual financial statements | 31 March of the following year (for NSI filing); 30 June for Trade Register publication | Small companies: simplified form; larger companies: full IFRS or Bulgarian GAAP statements with auditor’s report |
| Statistical reporting (NSI) | 31 March of the following year | National Statistical Institute annual report |
The Global Minimum Tax (Pillar Two) — Does It Affect Your Business?
What the 15% Global Minimum Tax Is
Since 2024, the EU has been implementing the OECD’s Pillar Two global minimum tax, which requires EU member states (including Bulgaria) to ensure that large multinational groups pay a minimum effective corporate income tax rate of 15%. Bulgaria has incorporated the relevant EU Directive into its domestic law.
This has created concern among some foreign business owners that Bulgaria’s 10% corporate tax rate is being raised. The concern is understandable but misplaced for the vast majority of businesses. The scope of the global minimum tax is deliberately and precisely defined to affect only the largest corporations.
Who Is Affected
| Group Characteristic | Subject to Global Minimum Tax? | Why |
|---|---|---|
| Multinational or domestic group with consolidated annual revenue above €750 million | Yes — subject to Bulgarian Pillar Two top-up tax where effective rate is below 15% | The €750 million threshold is the OECD/EU Pillar Two scope condition; groups above this threshold must ensure effective rates meet the 15% minimum |
| Individual company or group with consolidated annual revenue below €750 million | No — Bulgarian standard 10% CIT applies without modification | The overwhelming majority of SMEs, EEODs, OODs, and international businesses registered in Bulgaria fall below this threshold |
| Single-owner Bulgarian EOOD with revenue up to €5 million/year | No | Far below €750 million threshold; standard 10% applies |
| Group of Bulgarian companies owned by the same investor with total revenue below €750 million | No | Below threshold; standard 10% applies |
| Subsidiary of a large multinational (e.g. a Bulgarian R&D or services entity of a major corporation) | Potentially yes, if the global group exceeds €750 million | The top-up tax may be triggered at the group level; the Bulgarian entity itself pays 10% CIT as normal; any top-up is applied at the group level |
Euro Adoption and Corporate Taxation — What Changed
1 January 2026: Bulgaria Joins the Eurozone
Bulgaria adopted the euro on 1 January 2026, replacing the Bulgarian lev (BGN) at a fixed exchange rate that had been maintained for over two decades under the currency board arrangement. The transition to the euro has affected many aspects of Bulgarian business operations — but the corporate income tax rate is not among them.
| Aspect of Bulgarian Corporate Tax | Effect of Euro Adoption |
|---|---|
| CIT rate | Unchanged — 10% flat rate confirmed; euro adoption did not trigger any tax rate changes |
| Tax base calculation | All accounting now in euros; no conversion calculations required; simplifies reporting for companies earning in euros |
| Advance payment thresholds | Thresholds converted to euro equivalents; same economic thresholds apply |
| NRA filings | All tax returns, payments, and communications now in euros; eliminates BGN/EUR conversion in tax accounting |
| Invoicing and contracts | All company invoices, contracts, and financial statements now in euros; eliminates FX risk for eurozone trade partners |
| Cross-border dividend withholding | Withholding tax calculations no longer require BGN/EUR conversion; euros remitted directly |
| DTT treaty rates | All treaty rates apply to euro amounts directly; no conversion required |
How Bulgaria Compares to Other EU Jurisdictions
Corporate Tax Rates Across the EU
The table below compares corporate income tax rates across EU member states. The first section shows headline CIT rates; the second section shows the combined owner-level burden (CIT plus dividend tax) that determines how much profit a business owner actually retains after extracting earnings from their company.
| Country | CIT Rate | Dividend Tax | Combined Owner-Level Burden |
|---|---|---|---|
| Bulgaria | 10% | 5% | ~14.5% |
| Hungary | 9% | 15% | ~22.7% |
| Ireland | 12.5% | 25% | ~34.4% |
| Cyprus | 12.5% | 0% (to resident company) / 17% to individuals | ~12.5-28% |
| Romania | 16% | 10% | ~24.4% |
| Lithuania | 15% | 15% | ~27.8% |
| Slovakia | 21% | 7% | ~26.5% |
| Czech Republic | 21% | 15% | ~32.9% |
| Estonia | 0% retained / 22% distributed | Included | ~22% on distribution |
| Poland | 19% | 19% | ~34.4% |
| Netherlands | 25.8% | 26.9% | ~45.8% |
| Austria | 23% | 27.5% | ~44.2% |
| Belgium | 25% | 30% | ~47.5% |
| Germany | ~30% | 25% + solidarity | >47% |
| France | 25% | 30% (PFU) | ~47.5% |
| Spain | 25% | 19-28% | ~39-45% |
| Italy | 24% | 26% | ~43.8% |
| Denmark | 22% | 42% | ~54.8% |
Bulgaria vs. Romania vs. Cyprus vs. Estonia — Which Is Better for Your Business?
The Four Most Frequently Compared Jurisdictions for International Entrepreneurs
When internationally mobile entrepreneurs consider EU incorporation, these four jurisdictions appear most frequently in the analysis. Each has genuine advantages; the right choice depends on the business profile.
| Factor | Bulgaria | Romania | Cyprus | Estonia |
|---|---|---|---|---|
| CIT rate | 10% | 16% (1% micro-entity rate exists for micro-companies below €500K) | 12.5% | 0% retained / 22% distributed |
| Dividend tax | 5% | 10% | 0% (company) / 17% (individuals) | Included in 22% distribution rate |
| Combined on-extraction | ~14.5% | ~24.4% | ~12.5-28% depending on structure | ~22% |
| Personal income tax | 10% flat | 10% flat | 0-35% (scale) | 20% (from 2025) |
| EU / Schengen / Eurozone | All three since 2024/2026 | EU + Schengen; not eurozone | EU + eurozone; not Schengen | All three |
| Physical residency practical? | Yes — strong lifestyle case; low cost of living | Yes — Bucharest emerging; language barrier higher | Yes — English widely spoken; higher cost | Yes — digital governance; higher cost |
| Company registration for non-residents | EOOD/OOD — standard; no residency required | SRL — standard; local director sometimes required in practice | Ltd — standard; local director typical | OU — e-Residency allows remote; no physical residency required |
| Best for growth companies (reinvesting profits) | Moderate — 10% CIT applies annually even on retained | Moderate — 16% applies annually | Moderate — 12.5% applies annually | Strong — 0% on retained profits maximises reinvestment capital |
| Best for mature profitable companies (distributing dividends) | Best in EU — ~14.5% combined | Good — ~24.4% combined | Competitive — depends on structure | Less optimal — 22% on distribution |
Common Mistakes Foreign Owners of Bulgarian Companies Make
| Mistake | Why It Happens | Consequence | Prevention |
|---|---|---|---|
| Assuming company registration creates personal tax residency | Belief that registering an EOOD and obtaining a VNJ automatically shifts personal tax obligation to Bulgaria | Person remains tax resident in prior country; expected personal tax savings not materialised; potential double taxation | Understand that company registration and personal tax residency are legally separate; establish genuine Bulgarian tax residency independently |
| Mixing personal and corporate expenses | Owner treats the company account as a personal account; personal costs paid through company | Non-deductible expenses disallowed by NRA; reclassified as hidden profit distributions; dividend tax + penalties | Maintain strict separation of company and personal finances; pay personal expenses from personal accounts only |
| Withdrawing funds without dividend documentation | Owner transfers funds from company to personal account without a participants’ resolution | Irregular withdrawal; reclassified as undocumented income or hidden dividend; penalties, interest, potential audit | Always pass a formal dividend distribution decision before any withdrawal; document everything |
| Ignoring double taxation treaty provisions | Owner not aware of DTTs or assumes Bulgarian 10% is the only obligation | Unexpected withholding taxes on payments from foreign clients; missed credit opportunities; potential double taxation | Analyse the DTT between Bulgaria and each country where clients are located before the first invoice is issued |
| Missing the annual return deadline | Owner not aware of the 30 June deadline; accountant not engaged | Penalty for late filing; interest on late payment; NRA enforcement action | Engage Bulgaria for Business VCC from company registration; annual compliance is a standard part of the service |
| Not registering for VAT when the threshold is exceeded | Owner not monitoring revenue; unaware of the €50,000 VAT registration threshold | Retroactive VAT liability; penalties and interest from the point the threshold was exceeded | Monitor revenue against the VAT threshold monthly; register proactively before the threshold is crossed |
Why Bulgaria Remains the EU’s Most Competitive Corporate Tax Jurisdiction
Six Structural Advantages That Work Together
Bulgaria’s corporate tax competitiveness is not simply a function of the headline 10% rate. It is the product of six structural features that work together to produce an environment that is both low in cost and high in quality of market access.
| Advantage | Detail | Significance Rating |
|---|---|---|
| 10% flat CIT — no progression, no surcharges | The same rate applies from €1 to €1,000,000,000 of profit; no municipal surcharge; no special levies | Highest |
| 5% dividend tax — lowest in EU | Combined with 10% CIT produces ~14.5% owner-level burden; no social contributions on dividends | Highest |
| Full EU single market access | A Bulgarian company operates within the EU legal framework; invoices EU clients without tariffs; benefits from EU regulatory equivalence | Very high |
| Schengen membership (since 2024) | Goods, services, and people move without border controls; logistics efficiency for trade-dependent businesses | Very high |
| Eurozone membership (since 2026) | Euro-denominated transactions; no BGN/EUR conversion; institutional investor eligibility; sovereign credit upgrade | High |
| Political and legal stability of the tax framework | 10% CIT rate stable for nearly two decades; dividend rate stable; global minimum tax affects only €750m+ groups; no announced rate increases | High |
