Bulgaria Tax Residency Rules Every EU Founder Should Know

Why this is the most important page on the site

Owning a Bulgarian company gives you corporate access to the 10% rate. Becoming a Bulgarian tax resident unlocks the 10% personal rate and 5% dividend tax. The two are independent. Get residency wrong and you keep paying Western European tax personally — even though your company is in Sofia.

How you become a Bulgarian tax resident

Bulgarian law treats you as a tax resident if any one of these is true:

1. You have a permanent address in Bulgaria (registered residence)
2. You spend more than 183 days in Bulgaria in any 12-month period (counted over the calendar year)
3. Your centre of vital interests is in Bulgaria — family, main home, main economic activity
4. You are sent abroad by the Bulgarian state or a Bulgarian employer

How you stop being a resident elsewhere

This is the part founders underestimate. Common exit traps:

• Germany: unlimited tax liability persists until you can prove you've severed your Wohnsitz and gewöhnlichen Aufenthalt. Exit tax (Wegzugsbesteuerung) applies on >1% shareholdings.
• France: you remain resident if your foyer or principal place of stay is in France. Exit tax above EUR 800k.
• Netherlands: deregistration at the gemeente is necessary but not always sufficient; the conserveerende aanslag freezes substantial-interest gains.
• Spain: 183 days + centre of economic interests + family presumption. The 720 form reporting trails you.
• Italy: AIRE registration plus actual move; the 2024 reform tightened residency triggers.

Always engage a tax adviser in your departing country before the move.

The tie-breaker if both countries claim you

Bulgaria has tax treaties with every EU member state. Tie-breaker order is standard OECD:

1. Permanent home available
2. Centre of vital interests
3. Habitual abode
4. Nationality
5. Mutual agreement procedure

Documenting the move

Build a paper trail you can show either tax authority:

• Rental contract or property deed
• Address registration / Adresregistratie equivalent
• Utility bills in your name
• Bulgarian bank statements
• Mobile phone contract
• School enrolments (if family)
• Family doctor registration
• Travel records (flight bookings, border stamps)
• Bulgarian tax residency certificate (request annually from the NRA)

Common myths

• ❌ "183 days outside my old country is enough" — usually not; the old country's law decides what makes you exit
• ❌ "I can keep my apartment back home and just visit" — that's a permanent home available, and a major treaty trigger
• ❌ "The company is in Bulgaria so I'm fine" — corporate residency ≠ personal residency

Bottom line

A clean move means breaking old residency, establishing Bulgarian residency, and documenting both. Done properly, you lock in a single-digit effective personal tax rate inside the EU.