France SASU vs Bulgaria EOOD: Real Tax Comparison for French Founders (2026)

France is one of the highest-cost places in the EU to take money out of your own company. Between corporate tax, the flat tax on dividends and the social charges attached to a president''s remuneration, a French founder often keeps barely half of the profit their company earns. Bulgaria sits at the other end of the scale: 10% corporate tax, 5% dividend tax, and a company you can register remotely in under a week.

This guide puts the two side by side with 2026 rates, then covers the part most articles skip: when moving is realistic, what French exit tax does, and what substance you actually need in Bulgaria.

The headline rates in 2026

Item	France (SASU / SARL)	Bulgaria (EOOD / OOD)
Corporate tax	25% standard (15% on the first EUR 42,500 of profit if turnover under EUR 10m)	10% flat, no brackets
Dividend tax	30% flat tax (12.8% income tax + 17.2% social levies)	5% final withholding
Effective on distributed profit	roughly 47.5%	14.5%
VAT standard rate	20%	20%
Minimum share capital	EUR 1	BGN 2 (about EUR 1)
Annual accounting cost	EUR 1,500 to EUR 3,000	EUR 500 to EUR 1,200
Time to register	1 to 3 weeks	3 to 7 working days

The maths on EUR 100,000 of profit is blunt. In France, 25% corporate tax leaves EUR 75,000, and the 30% flat tax on the dividend leaves EUR 52,500 in your hand. In Bulgaria, 10% leaves EUR 90,000, and 5% dividend tax leaves EUR 85,500. That is a EUR 33,000 gap on a single year, before you count the difference in accounting fees and social contributions.

The full breakdown of how the Bulgarian side works is in our 10% corporate tax guide and the dividend tax guide.

Where the French cost really comes from

The 25% corporate rate is not the problem. France is mid-table in Europe on corporate tax. The cost sits in three places:

Social charges on remuneration. A SASU president on the assimilated-employee regime pays combined employer and employee charges of roughly 75% to 80% of net salary. Paying yourself EUR 40,000 net can cost the company close to EUR 70,000. A SARL gerant majoritaire under the TNS regime pays less, roughly 45%, but still far above the Bulgarian equivalent.

The 17.2% social levy on dividends. This is what turns France''s 12.8% dividend income tax into a 30% flat tax. There is no participation exemption for an individual shareholder.

Compliance friction. Annual accounts, a French accountant on retainer, URSSAF declarations, and the CFE local business tax add up long before you look at the tax bill itself.

In Bulgaria, a manager can be insured as a self-insured person on a declared income base, with social contributions capped. Total monthly social cost for a solo founder typically sits between EUR 180 and EUR 450 depending on the declared base. Our payroll and employer cost page has the 2026 contribution tables.

What French exit tax does and does not do

If you personally leave France after having been tax resident there for six of the previous ten years, and you hold shareholdings worth more than EUR 800,000 or more than 50% of a company''s profits, the exit tax (article 167 bis CGI) applies to unrealised capital gains on those shares. Moving inside the EU normally gives you an automatic deferral of payment, and the charge is cancelled if you hold the shares long enough after departure, currently two or five years depending on the value.

Three practical points:

• Exit tax is about your personal shares, not about incorporating a new company abroad. Starting a fresh Bulgarian EOOD for new business does not trigger it.
• Deferral inside the EU is automatic, but you still have to declare it on form 2074-ETD. Missing the declaration is what causes problems, not the move itself.
• If your French company keeps trading, it keeps paying French tax. Bulgaria taxes what the Bulgarian company earns.

We cover the equivalent German rule in the Wegzugsteuer guide, and the mechanics are similar enough that it is worth reading if you are comparing routes out of a high-tax country.

Substance: the part that decides whether this works

A Bulgarian company that exists only on paper while you continue to live and work in Paris is a French company with a Bulgarian address, and the French administration will treat it as such under the place-of-effective-management rule in article 4 of the France-Bulgaria double tax treaty. The structure works when the decisions genuinely happen in Bulgaria.

What that means in practice:

• Management presence. The manager should spend meaningful time in Bulgaria and sign contracts there. If you are the sole decision-maker and you never leave France, effective management is in France.
• A real address. Not a mailbox. See the registered office guide for what counts and what does not.
• Local banking and bookkeeping. A Bulgarian bank account with real activity, monthly bookkeeping filed locally. Our business bank account guide lists which banks work with non-residents.
• Personal tax residency. If you want the 5% dividend rate to be the end of the story, you generally need to stop being French tax resident. Otherwise France taxes your worldwide dividend income and gives credit only for the 5% already paid.

The honest version: this structure is excellent for founders who are genuinely mobile, run a location-independent business, and are willing to move their centre of life. It is a bad idea for a French-market consultancy serving French clients from a French home office.

Cost and timeline of the Bulgarian side

Registration of an EOOD takes 3 to 7 working days once documents are ready. You do not need to travel: a notarised and apostilled power of attorney lets us file on your behalf. The full document list is in the registration documents guide.

Typical first-year budget:

• Formation, including state fee, notary, translation and legal work: from EUR 399
• Registered office address: EUR 120 to EUR 300 per year
• Monthly accounting: EUR 50 to EUR 150 depending on transaction volume
• VAT registration when needed: usually 7 to 14 days, see the VAT registration guide

Compare that against a French SASU''s typical EUR 1,500 to EUR 3,000 annual accounting retainer plus CFE, and the running cost difference alone pays for the move in year one.

Does the France-Bulgaria treaty help?

Yes, in two ways. It caps Bulgarian withholding on dividends paid to a French resident at treaty rates, though Bulgaria''s domestic 5% is already below most treaty caps, and it sets tie-breaker rules for residency if both countries claim you. What it does not do is let you keep living in France and pay Bulgarian rates. Treaties allocate taxing rights; they do not create a choice.

When a SASU still wins

Be fair to France. Keep the SASU if:

• Your clients are French public bodies or large French corporates that will not contract with a foreign entity.
• You rely on French innovation regimes such as the CIR research credit or JEI status, which have no Bulgarian equivalent of the same scale.
• Your family and life are anchored in France and you have no intention of moving.
• You are pre-revenue and the admin cost of a second jurisdiction outweighs the tax saved.

Frequently asked questions

Can I own a Bulgarian EOOD while living in France?

Yes, ownership is unrestricted. But if you manage the company from France, France can treat it as French tax resident and tax its worldwide profit. Ownership is not the issue, management is.

Do I need to speak Bulgarian or travel to Bulgaria?

No for registration, which is done under power of attorney. But if you want real substance, some presence in Bulgaria is part of the picture.

What is the total effective tax rate on Bulgarian profit?

14.5% on distributed profit: 10% corporate tax, then 5% on the remaining 90%. If you leave profit in the company, it is 10%.

Will my French accountant need to keep filing?

If the SASU stays open, yes. Many founders wind the French entity down once the Bulgarian company takes over trading, but that is a decision to take with a French adviser.

How long before the Bulgarian company can invoice?

Usually within a week of filing, once the Commercial Register entry and the company bank account are in place. See the formation timeline.

Next step

If you want the numbers on your own figures, run them through the tax calculator or book a free consultation. We register OOD and EOOD companies remotely from Varna, and we will tell you plainly if your situation is one where staying in France is the better call.