Page 14 - CEE Tax Guide 2025

Bulgaria

Forvis Mazars Consulting OOD
3A Moscovska str.,1000
Sofia, Bulgaria
Phone: +359 287 800 02
www.forvismazars.com/bg

Corporate taxes and other direct taxes registered in an EU Member State subject to some
additional requirements.
Bulgaria has a flat corporate income tax rate
of 10%, applied to the annual tax profit reduced 1) Bulgaria has National top-up tax on profits
by tax losses carried forward within five subsequent of multinational enterprise (MNE) groups and
years. Bulgaria applies thin capitalization rules large-scale domestic groups. There is a threshold
to interest expenses from loans or leasing provided of 750 million euro (for the previous two years)
or guaranteed by related parties. Advance tax on group level calculated in the consolidated
payments should be made each month or quarter, report of the group. The Global Minimum Tax
based on the estimated tax profit for the could be applied if the criteria for the national
current year. top-up tax are not met. The rate is a maximum
of 15% on the profits.
Withholding tax rates are 5% for dividends and
10% for exhaustively listed other income from 2) Local taxes are determined by each municipality
source in Bulgaria, including capital gain, gain within the ranges stated in the Local Taxes and
from sale of immovable property, interests and Fees Act. Local taxes and fees include:
royalties. (Double Tax Treaties can be applied
to decrease or eliminate the withholding tax). There – real estate tax: the tax rate is in the range of 0.1%
is no withholding tax if the dividends, interests, and to 4.5%. The base for taxation of non-residential
royalties are paid in favour of a parent company real estates of companies is the higher of the book
value or the value calculated by municipality tax
valuation. The base for taxation of all residential
Transfer pricing in Bulgaria real estate is the municipality’s tax valuation;
Arm’s length principle Since 1989 – transportation vehicle tax: determined as an exact
amount, depending on vehicle type and power;
Documentation liability A TP local file is obligatory – gift tax: applied to gifts of all kinds, with very
for companies subject
to some criteria. limited exemptions. Applies also to forgiven
payables. There are two ranges of rates
APA No –
applicable: between 0.4% and 0.8% for gifts
Country-by-Country Yes between siblings and their children; and between
liability 3.3% and 6.6% for all other gifts;
Master file-local file Where the company – tax on the acquisition of property for
(OECD BEPS 13) required to prepare a consideration: applies to real estate, vehicles,
applicable an LF is an MNE member.
and limited real estate rights acquired for
Penalty a consideration. The tax rate range is between
0.1% and 3% of the value of the property, or,
lack of documentation 0.5% for lack of local file;
BGN 5,000 to 10,000 for in the case of exchange, the value of the more
lack of a master file. expensive property;
– inheritance tax: exempt to a limited extent
tax shortage BGN 1,500 to BGN 5,000
(family members);
Related parties 50% < Direct or indirect control, – patent tax: applied to micro enterprises
or personally related.
or individuals whose activities are small services
Safe harbors No – such as tailoring, very small stores, carpentry, etc.
These are fixed amounts, determined by each
Level of attention paid 10/10
by Tax Authority municipality;

Central and Eastern European tax guide 2025 Forvis Mazars 14