Forming a Bulgarian company is the easy part. Becoming a Bulgarian tax resident, and being able to prove it when your old country asks, is what actually delivers the 10% corporate and 5% dividend rates. This guide sets out the 2026 rules, the tests that decide the outcome, and the documents that settle arguments.
The four tests for Bulgarian tax residency
Under the Bulgarian Personal Income Taxes Act, you are a tax resident individual if any one of these is true:
- You have a permanent address in Bulgaria, subject to the centre of vital interests test below
- You spend more than 183 days in any 12-month period in Bulgaria
- You were sent abroad by a Bulgarian employer or the Bulgarian state
- Your centre of vital interests is in Bulgaria
The 183-day count is the most cited but the fourth test is the one that decides difficult cases. Centre of vital interests looks at family, property, employment, where your business is managed and where your economic ties sit. A permanent Bulgarian address alone does not make you resident if your life is demonstrably centred elsewhere.
Counting the 183 days
The count runs over any rolling 12-month period, not the calendar year. Days of arrival and departure both count as days present. Days spent in Bulgaria solely for education or medical treatment are excluded.
Keep evidence as you go: boarding passes, entry and exit stamps where relevant, rental agreements, utility bills and card statements showing local spending. Reconstructing a year of travel from memory two years later, under audit, is the worst place to be.
What your old country still claims
Leaving is not automatic. Most European countries apply their own residence tests and several keep claims after departure:
- Germany applies extended limited tax liability and exit taxation on substantial shareholdings, covered in the Wegzugsteuer guide
- The Netherlands looks at a durable personal tie and the DGA salary rules, see the Dutch relocation guide
- Spain applies a 183-day test plus a centre of economic interests test, see the Spain comparison
- France applies exit tax under Article 167 bis CGI, see the France comparison
- US citizens remain taxable on worldwide income regardless of residence, see the FEIE guide
Where two countries both claim you, the applicable double tax treaty tie-breaker decides, in order: permanent home, centre of vital interests, habitual abode, then nationality.
Company residence is a separate question
Your personal residence and your company's tax residence are decided separately. A Bulgarian EOOD managed day to day from abroad can be treated as tax resident in that other country under place of effective management rules, which erases the benefit. Substance for the company means local decision making, a real registered office, a Bulgarian bank account and local accounting and filings.
The paperwork that proves residency
- A Bulgarian address registration and long-stay documentation appropriate to your nationality
- An EGN or personal number issued by the authorities
- A tax residency certificate from the National Revenue Agency, issued on request once the conditions are met
- A Bulgarian annual personal tax return, filed even where tax due is nil
- Bank, lease and utility records showing continuous presence
The residency certificate is what foreign tax authorities and banks actually ask for. Plan to apply for it in the year after you first meet the tests.
Personal tax once you are resident
Bulgaria applies a flat 10% personal income tax on most income and 5% on dividends. There are no regional surcharges and no progressive bands. Social contributions apply on employment and self-employment income up to a capped base, detailed in the payroll and employer cost guide.
If you run your business through an EOOD, the practical route is a modest manager's salary plus dividends, described in the dividend tax guide.
A realistic first-year sequence
- Decide the departure date and settle exit obligations in your current country
- Form the EOOD, see the documents checklist
- Secure a Bulgarian address and open the company bank account
- Register for VAT if your activity requires it, see the VAT guide
- Track presence from day one and pass 183 days within the rolling window
- Apply for the tax residency certificate and file the first Bulgarian return
Frequently asked questions
Do I need to be in Bulgaria for 183 days if my centre of vital interests is there?
No. The tests are alternatives. But relying on centre of vital interests alone without meaningful presence invites challenge from the country you left, so most founders aim to meet the day count in the first year.
Can I be tax resident nowhere?
In practice no. Countries you leave will continue to treat you as resident until you demonstrate residence elsewhere. A residency certificate from Bulgaria is the cleanest way to close that door.
Does a digital nomad visa make me tax resident?
Not by itself. Immigration status and tax residence are separate. The tax tests above are what count.
Do I still pay tax in the country where my clients are?
Generally no for services delivered from Bulgaria, though a fixed place of business in a client's country can create a permanent establishment there. Keep operations genuinely centred in Bulgaria.
Can EU citizens simply move?
EU and EEA citizens have free movement rights and register with the migration directorate for long stays. Non-EU nationals need an appropriate residence route before the day count becomes practical.
Next step
Estimate your position with the tax calculator, read the EOOD explainer, then book a free consultation to map the sequence for your country.
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