A review of your circumstances and planned transactions, with clear guidance on the relevant taxes, documents, filings and next steps.
A client asked ARG how Bulgarian tax rules applied to their circumstances. Immediate filing obligations and planning decisions needed to be separated before the work could proceed. ARG established the facts, documented the relevant tax position and organised the tasks in one checklist. The client could follow the work and received consistent guidance on what required attention.
A consultation needs the same factual starting point. The review identifies the person or company earning each income stream, the transaction date and the countries involved. Contracts, invoices, residence evidence and previous filings help establish the questions requiring an answer. Corporate tax, VAT, financial-statement publication and personal tax may involve separate obligations, even where they arise from the same business arrangements.
ARG can help when you need to
Tell us what you plan to do or need to correct, when it happens and which tax year is affected.
Separate personal income, company transactions and payments between the company and its owners.
Bring contracts, income records, prior returns, foreign tax evidence and relevant NRA correspondence.
Include transaction, travel and notice-service dates so registration, filing and response deadlines can be identified.
The Corporate Income Tax Act (Закон за корпоративното подоходно облагане, ЗКПО) governs Bulgarian corporate income taxation and the principal annual corporate-tax filing. The corporate income-tax rate is 10% under Art. 20. For entities required to file, the annual return under Art. 92 is submitted electronically between 1 March and 30 June of the following year, and the annual corporate tax is payable by 30 June.
A Bulgarian company and its shareholder are separate taxpayers. Money paid by an owner may be capital, a documented loan or payment for a supply; money paid back may be remuneration, reimbursement, loan repayment or dividend. Each classification has different tax, accounting and evidence requirements. Before comparing rates, identify who earned the income and what legal event created the payment. Bring the contract, company decision, invoice or expense evidence, together with the bank movement, so the consultation starts from the transaction rather than its bank-reference description.
The annual activity report is generally filed through the Art. 92 process where applicable. Under the NRA’s filing guidance, statutory inactivity generally removes the annual-return obligation, except where corporate tax or tax on expenses is due or the taxpayer wishes to declare other information. Inactive entities do not submit an annual activity report. No profit or sales alone does not establish inactivity. Review bank movements, contracts, expenses, management actions and other transactions.
The Accountancy Act (Закон за счетоводството, ЗСч) governs accounting records, financial reporting and publication obligations. Filing the corporate-tax return does not itself complete a company’s annual compliance. For entities within the statutory publication regime, the Registry Agency confirms that annual financial statements must be filed for announcement in the Commercial Register/Register of Non-Profit Legal Entities by 30 September of the following year.
Assess mandatory independent audit separately under Art. 37 of the Accountancy Act against the entity’s legal form and current financial circumstances. Incorporation, turnover alone or a foreign parent’s practice does not settle that question. Plan the accounting close, tax deadlines and publication timetable together.
VAT is assessed separately from income tax. From 1 January 2026, a person established in Bulgaria generally applies for compulsory registration when annual domestic turnover exceeds€51,130, within 7 days after crossing; registration takes effect from the following day. The relevant turnover is the calendar-year amount defined by the VAT Act, not the old rolling 12-month measure. Establishment, excluded supplies and the previous year’s turnover can change the route. A foreign supplier may face obligations from its first relevant taxable supply, so the Bulgarian threshold cannot be assumed to protect every overseas business. NRA current VAT registration guidance
Arts. 97a and 99 provide separate registration bases in specified cross-border-service and intra-Community-acquisition situations. A Bulgarian consultant invoicing an EU business customer, a company purchasing services from abroad, or a business acquiring goods within the EU may need registration analysis before reaching that threshold. The relevant facts include the precise service or goods supplied, customer status, customer location, supplier establishment, invoice flow and the timing of transactions.
The EU VAT Directive (Council Directive 2006/112/EC) provides the EU framework for these cross-border questions. Under Arts. 44 and 196, the usual B2B rule is that a service is supplied where the business customer is established, with VAT generally accounted for by the customer under reverse charge where the supplier is not established in the Member State in which VAT is due. Check the conditions and exceptions against the transaction evidence before applying the rule.
In CJEU, Berlin Chemie A. Menarini, judgment of 7 April 2022, Case C-333/20, ECLI:EU:C:2022:291, the Court held that an affiliated local provider of marketing, regulatory, advertising and representation services did not, merely through that relationship, create a VAT fixed establishment for the foreign company. A fixed establishment requires sufficient permanence and human and technical resources enabling the business to receive and use services for its own needs. Group affiliation, a Bulgarian service provider or local VAT registration alone does not decide the result. The judgment concerns VAT fixed establishments, not corporate-income-tax permanent establishment.
The UK–Bulgaria Double Taxation Convention, as modified by the Multilateral Instrument (Спогодба между Република България и Обединеното кралство Великобритания и Северна Ирландия за избягване на двойното данъчно облагане; MLI) addresses treaty scope, residence, permanent establishment and double-tax relief in Arts. 1, 4, 5 and 21. It may be relevant to an individual or company with a genuine Bulgarian and UK connection, but only after the actual residence, income type, ownership and operational facts have been established.
The synthesised text records MLI application from 1 January 2023 for withholding taxes in both states and, for other Bulgarian taxes, for taxable periods beginning on or after 1 January 2024. Treaty analysis does not remove the need to examine domestic returns, evidence of foreign tax residence, tax withheld abroad, beneficial ownership where relevant and applicable anti-abuse considerations. For connections with other states, review the relevant domestic rules and treaty.
A useful starting question is concrete: “Must I file for this year?”, “How should the company pay its working owner?”, “Does this contract require VAT registration?” or “What happens if I move while keeping my foreign business?” Provide the year and date of the planned step. The same transaction can involve personal income tax, corporate tax, VAT and social insurance, but each has its own taxpayer and trigger.
For a personal review, start with tax residence under Article 4 of the Personal Income Tax Act and then classify each income under its own rules. Residents generally account for worldwide taxable income; nonresidents are assessed on Bulgarian-source income. A Bulgarian bank account does not turn every incoming transfer into Bulgarian income, and payment abroad does not remove the Bulgarian source of rent from Bulgarian property. Contracts, ownership records and the actual work location usually explain more than the transfer route. Personal Income Tax Act Articles 4,6–8
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.
Send the decision you need to make, the affected tax year and any approaching deadline first. Then provide the underlying documents in date order: income and employment records for an individual, or contracts, invoices, ledger extracts and prior returns for a company. Include NRA letters with their service dates. This lets us distinguish a planning question from a registration, return, correction or appeal that already has a statutory deadline.
The Tax and Social Security Procedure Code governs tax procedure, audits and the powers of the revenue authority. Under Art. 122, where statutory indicators exist, the National Revenue Agency may determine a tax base by analogy. Indicators include unreported revenue, a missing required return, false documents and absent or unproduced accounting records. Retain contracts, bank evidence, invoices and accounts to substantiate the transactions.
The Berlin Chemie judgment, C-333/20,7 April 2022 shows why a VAT fixed establishment needs its own factual analysis. An affiliated local service provider did not by that fact alone give the foreign recipient a suitable structure for receiving and using the services. In your records, identify which company controls the people and technical resources, what they do and which establishment receives the service. Do not treat this VAT judgment as a general exemption from corporate permanent-establishment, payroll or registration rules: those ask different legal questions.
Check readiness before implementation. Incorporation alone does not settle VAT invoicing for an EU customer, immigration status does not establish tax residence, and apparent inactivity still requires review of the company’s transactions.
ARG organises the consultation into conclusions, missing evidence and the next action for each taxpayer. The outcome should identify the relevant income or transaction, legal trigger, calculation basis, responsible filer and deadline. Where implementation requires accounting entries, payroll changes, a foreign certificate or a corporate decision, those tasks are assigned in the action plan. A clear instruction to the accountant is more useful than a list of tax rates detached from the documents.
Provide the intended Bulgarian presence or business model, relevant countries, expected income or transactions and available documents. The review can then identify decisions needed before relocation, incorporation, first invoicing or the next filing deadline.
An ordinary personal return is generally due by 30 April, while sole-trader and qualifying trader-income returns use the 1 March–30 June window. Corporate returns are filed from 1 March to 30 June with payment by 30 June. Quarterly withholding, monthly VAT and event-based registrations have separate deadlines. Put these on the same calendar without assuming an annual return cures an earlier missed registration.
If a return has already been filed, bring the submitted version and receipt. The ordinary one-off correction by 30 September has defined scope; other errors can require a different notification or correction procedure. If the NRA has started a check or audit, the request, scope and service date determine the immediate response. Preserve original invoices and communications and explain discrepancies through a dated reconciliation. A reconstructed commercial explanation should not replace documents showing what actually happened. ZKPO Articles 75,79,92–93
Compare the related procedures in this category, including their requirements and the stage at which you need them.
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