Corporate Tax Return Preparation in Bulgaria

We reconcile accounting results with the corporate tax calculation, prepare the annual return and coordinate electronic submission to the NRA.

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Published
07.06.2024

A company’s annual tax return can look like a final form to complete, but the difficult part often comes earlier. One ARG client had started preparing the return without a clear view of how it fitted into the company’s wider accounting. ARG checked the supporting records and organised the work around the monthly and year end reporting, including the steps leading up to the return.

This is the practical issue many Bulgarian companies face. The return must reflect the company’s tax financial result, but the filing decision can also depend on activity status, foreign tax, ownership structure, group information and the way the submission is authorised. Understanding those points early helps prevent a completed calculation from becoming an incomplete filing.

ARG can help when you need to

  • Check whether your Bulgarian company must file an annual corporate tax return
  • Assess whether the no activity exemption applies to your company’s year
  • Organise accounting, foreign tax, ownership and group documents for filing
  • Coordinate electronic submission through the NRA portal before 30 June

At a glance

(001)
Taxpayer and activity

Confirm the company’s tax status, full-year activity and any Bulgarian permanent establishment; zero sales alone does not establish exemption.

(002)
Reconciled tax calculation

Provide final accounts, a tax-adjustment schedule, depreciation records, loss history and credited advance payments.

(003)
Cross-border evidence

Collect foreign-tax proof and applicable ownership or group disclosures; identify the correct treaty method and reporting year.

(004)
Signature and payment

Arrange authorised electronic access, review the acceptance notice and plan annual filing and payment by 30 June.

What is the Bulgarian annual corporate tax return, and which companies must file it?

The annual corporate-tax return under Article 92 of Bulgaria’s Corporate Income Tax Act, known as ZKPO, reconciles accounting profit or loss with the tax rules and declares the resulting liability. The ordinary corporate-tax rate is 10% of taxable profit. That is not 10% of turnover or money left in the bank: non-deductible expenses, tax depreciation, qualifying loss relief and other statutory adjustments can change the base. Prepare an itemised reconciliation from the final trial balance so each adjustment can be traced to a document and legal ground. NRA corporate-tax guidance

What that means in practice

If your company is within the Bulgarian corporate tax regime, the return is not just a formality. It is the legal vehicle for determining the year-end corporate tax position and confirming what is due for the tax period. That is why corporate tax return preparation is a distinct service, not merely a bookkeeping export. The work starts with deciding whether the entity is a corporate taxpayer, then checking the accounting result, adjustments, and any items that change the final tax base.

For a Bulgarian company, examine both domestic and foreign activity. A foreign legal entity may instead be taxed on profits attributable to its Bulgarian permanent establishment, meaning the local business presence through which the relevant activity is carried on. Registration of a branch is evidence of structure, but the tax analysis also depends on the actual place, people, contracts and functions. Non-profit status likewise does not exempt every commercial or rental activity. Identify the taxpayer and income category first, then determine what the annual return must cover and whether separate withholding or expenses taxes also arise.

Why this service is relevant

You need this service when you want a reviewed and properly sequenced annual filing for a Bulgarian company subject to corporate tax, especially if the result depends on accounting data, cross-border items, or ownership facts that affect the return. A simple year-end profit figure is not enough on its own. The return must reflect the tax result, and the preparation has to align the accounting records with the legal filing basis.

The practical question is not whether the company has a spreadsheet. It is whether the company has a defensible tax filing position.

For a client, that usually means one of two things. Either the company clearly falls within the annual filing duty and the preparation should be done on that basis, or the company’s legal status and year-end facts need to be checked first so you do not overstate or understate the obligation. That preliminary review is part of the value of the service.

In one view

  • The return covers the annual tax financial result and the annual corporate tax due.
  • The legal basis is Article 92, paragraph 1 of the ZKPO.
  • The duty concerns taxable persons subject to corporate tax in Bulgaria.
  • The key decision is whether the company needs a full filing review and preparation, not whether it simply had accounting records for the year.

When can a company with no activity avoid filing, and when must it still submit a return?

A company can avoid filing only in the limited no-activity case, and even then the exemption is not absolute. Article 92, paragraph 4 of the ZKPO says that if the taxpayer did not carry out activity within the meaning of the Accountancy Act during the tax period, the annual tax return and the annual activity report are generally not filed. See the National Revenue Agency text, Article 92, paragraph 4.

When the exemption applies

The inactivity test in Accountancy Act Additional Provisions § 1(30) requires all four statutory conditions throughout the reporting period: no relevant commercial transactions, no conditions for recognising revenue, no investment, production or selling activity, and no purchases intended to earn income or profit. A company preparing its first sales may already be active if it acquires business stock or services for that purpose. Review contracts, bank movements, asset purchases and expenses before relying on the exception. The tax-return exemption and the separate one-time Register inactivity declaration must each be assessed on their own terms. Accountancy Act, § 1(30)

When the company still has to file

The same paragraph makes clear that the exemption does not cover every no-activity case. A return still has to be filed if, despite no activity, a corporate tax obligation or an expenses tax obligation arose, or if the taxpayer wants to declare other data and circumstances provided in the return form. In other words, the absence of business operations does not automatically end the filing analysis.

That distinction matters in practice because clients often confuse no commercial turnover with no filing duty. Those are not the same thing. A company may have had no trading activity and still need to submit a return because another tax consequence arose or because the form must include specific declarable information. The legal question is therefore not only whether the company traded, but whether any taxable event or reportable fact exists.

What ARG checks before relying on non-filing

Before advising that the exemption can be used, ARG would test the year against the legal inactivity standard and the exceptions in Article 92, paragraph 4. The key points are whether any tax obligation arose, whether the annual activity report is also excused, and whether the return form must still be used to disclose other circumstances. If any of those items is present, the safe answer is not non-filing but proper filing.

For a client, the practical decision is straightforward. If the company was genuinely inactive and no exception applies, the filing burden may fall away. If there was any taxable or declarable item, the company should prepare a return instead of assuming that dormant status solves the problem. That is often the moment when a brief accounting review prevents an avoidable compliance mistake.

Let’s discuss your plans for Bulgaria

Tell us where you live, how your business works and what you want to change. We will help you identify the questions to resolve and the next steps to consider.

Which documents and disclosures can change how ARG prepares the return?

The documents that matter most are the ones that change the tax base, the filing package, or the identity disclosures. Under Article 92, paragraph 3 of the Corporate Income Tax Act [ZKPO], the annual activity report is filed together with the annual tax return. That means ARG does not treat the return as a stand-alone arithmetic exercise. It has to be prepared against the accounting records and the reporting package for the year so the filing reflects the company’s actual position, not just a year-end balance.

What can change the preparation

The law also requires supporting information in specific cross-border and ownership situations. Under Article 92, paragraph 6, if foreign tax has been paid, proof of the amount paid abroad must be attached unless the relevant double taxation treaty uses the exemption with progression method. In practical terms, that means ARG has to check whether the foreign tax evidence is available, whether it is sufficient, and whether the treaty position changes the attachment requirement. A foreign tax slip or payment confirmation can therefore become a filing document, not just a back-office record.

Article 92, paragraph 7 matters where the taxpayer is a foreign legal entity operating in Bulgaria through a permanent establishment. In that case, the return must also include identification data for owners, shareholders, or partners holding more than 10 percent. This is not a universal requirement for every Bulgarian company. It is a structure-specific disclosure that can only be completed correctly if the ownership chain is clear and documented.

Article 92(8) requires qualifying subsidiaries or branches of a third-country undertaking within Accountancy Act Article 52 b(1) or(4) to disclose the undertaking’s net sales revenue in Bulgaria and the EU for its latest reporting period. This is a defined statutory category, not every Bulgarian company with a non-EU shareholder. The transitional rule in § 37 of the 2024 Accountancy Act amendment applies the Article 92 disclosure to returns for 2026 and subsequent years. Establish the reporting year and qualifying structure before requesting group figures, and retain the calculation supplied by the parent. ZKPO, Article 92(8) and transitional provisions

What ARG needs from the client

The practical question is not only what the law asks for, but what evidence exists to support it. In a typical corporate tax return review, ARG would ask for the accounting trail, the annual activity reporting package where relevant, any foreign tax certificates or payment confirmations, ownership details for a permanent establishment case, and group revenue data if the company is a third-country subsidiary or branch. If any of those items is missing, the filing position may still be possible, but it needs to be tested before submission rather than guessed.

If a document changes the tax result, it is part of the filing problem, not an afterthought.

For the client, that means preparation should start before the statutory filing window opens, especially where the company has cross-border income, foreign tax relief, or non-Bulgarian ownership links. ARG’s role is to identify which facts actually trigger an attachment or disclosure, which facts are irrelevant, and which missing records need to be sourced before the return is finalised.

How is the corporate tax return filed electronically in Bulgaria, and what must the company arrange?

In practice, the Bulgarian annual corporate tax return is filed electronically through the National Revenue Agency portal, using a qualified electronic signature. The NRA’s operational guidance and service page confirm that electronic submission is the standard route for the return under Article 92, paragraph 1 of the Corporate Income Tax Act [ZKPO]. The separate service registry entry for acceptance of the annual return confirms the same filing route. This is a practical rule, not just a theoretical one. If the company cannot access the portal properly, or if the signatory is not arranged in advance, the return may be ready in substance but not properly filed.

What has to be arranged before submission

ARG usually has to make sure three things are aligned. First, the return content must be complete and internally consistent. Second, the person or professional who will submit it must have the right authority and access. Third, the qualified electronic signature must be available and usable for the actual filing event. Without that sequence, electronic filing becomes a technical bottleneck rather than a routine administrative step.

After electronic submission, distinguish the automatic incoming reference from the acceptance or rejection result. Retain the signed return and final processing notice, then reconcile the annual tax with advance payments credited to the company’s tax account. Under the NRA procedure, rejected data must be corrected through a compliant new declaration within seven days of the rejection notification. Assign someone to monitor the portal and registered email address so a technical rejection is handled while the remedy remains available. NRA submission and rejection procedure

A practical example

If a company has finished its accounting close but the director’s electronic signature is unavailable, the return is not truly ready for filing. In that case, ARG would need to identify whether another authorised person can submit it, whether access credentials need to be arranged, or whether the signing process itself needs to be corrected before the deadline. The issue is procedural, but it has the same commercial effect as a missing tax figure. The filing cannot move forward until the access problem is solved.

If an error is discovered after the ordinary filing deadline, Article 75(3) allows a one-time replacement return by 30 September for the preceding year where a return has already been filed. Article 79 extends the chapter to other errors and adjusting events, not merely arithmetic mistakes. Other cases under Article 75 require written notification to the competent revenue authority. Record the affected year, discovery date, original figures and correction, and calculate any additional tax and interest; submitting a corrected return does not itself pay the difference. ZKPO, Articles 75, 79 and 80

What must be completed by 30 June to meet the Bulgarian corporate tax filing deadline?

The filing window runs from 1 March to 30 June of the following year under Article 92, paragraph 2 of the Corporate Income Tax Act [ZKPO], and the return is filed with the territorial directorate of the National Revenue Agency where the taxpayer is registered. The practical consequence is that the company does not just need a completed return by the end date. It needs the whole filing chain finished by then, including the accounting review, any required disclosures, supporting evidence where foreign tax or ownership data apply, and the electronic submission itself.

That is why the final deadline is not only a calendar issue. It is the point at which every unresolved question becomes a filing risk. If the company still needs foreign tax confirmations, ownership information for a permanent establishment, or group revenue data for a third-country subsidiary or branch, those items have to be obtained and checked before the submission can be signed. The NRA guidance also confirms that the standard route is electronic filing through the e-services portal with a qualified electronic signature, so late preparation can become a technical problem as well as a legal one.

What should be completed before 30 June

A sensible preparation sequence is simple.

  • Confirm whether the company must file at all.
  • Finalise the accounting figures and tax adjustments.
  • Collect any foreign tax proof and structure-specific disclosures.
  • Check who is authorised to sign and submit electronically.
  • File through the NRA portal and keep the submission confirmation.

For the client, the practical implication is clear. If the company waits until the end of June to resolve the accounting or access questions, it may still miss the deadline even if the underlying tax position is straightforward. ARG’s role is to compress that sequence into a controlled filing process so the return is not only accurate, but actually submitted on time. In a cross-border company, that timing discipline is often the difference between routine compliance and an avoidable deadline problem.

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Questions and answers

01 / 06

Is corporate tax simply 10% of accounting profit?

The ordinary rate is 10%, but it applies to taxable profit after the adjustments required by ZKPO. Accounting expenses may be non-deductible or recognised in another year, and tax depreciation or available tax losses can change the result. Supply the final trial balance, expense support, asset registers and loss history. The return should include a reconciliation that explains each difference rather than copying the profit figure.

Does an inactive company always avoid the annual tax return?

No. Article 92(4) uses the Accountancy Act’s statutory inactivity definition, which is wider than having no sales. Even a qualifying inactive taxpayer files if corporate tax or expenses tax arises, or if it wishes to declare other data provided by the form. Review the whole year’s bank, contract, asset and expense records and assess the separate Register inactivity declaration.

What are the filing and payment deadlines?

The ordinary Article 92 return is filed electronically from 1 March to 30 June of the following year; annual corporate tax, after eligible advance payments, is due by 30 June. These are separate actions. Verify the authorised qualified electronic signature, retain the acceptance result and check that payment is credited to the correct taxpayer. Final returns following liquidation or termination can have special deadlines.

Can a filed corporate-tax return be corrected?

For an already filed preceding-year return after the ordinary deadline, Article 75(3) permits one replacement by 30 September of the current year in the covered circumstances. Article 79 also covers other errors and adjusting events. Other prior-year cases require written notification to the competent NRA authority. Prepare a documented reconciliation of the change and account separately for additional tax and interest.