8 September 20264 min readUpdated 9 Sep 2026
Polish CIT is 19% (9% for small taxpayers) plus up to 10.8% solidarity levy, while Bulgaria charges a flat 10% corporate and 5% dividend tax. Here are the real numbers on EUR 150,000 profit, CFC risks and what actually works in 2026.
Polish founders running service businesses, agencies and SaaS companies increasingly ask the same question: is the Polish Sp. z o.o. still the right structure when Bulgaria offers a flat 10% corporate tax an hour's flight away? This guide compares the real 2026 numbers, the Polish exit-tax and CFC rules that decide whether the move works, and the structure that survives a tax audit on both sides.
If you are short on time: the summary table below gives the headline rates, then we run the same EUR 150,000 profit through both systems.
| Item | Poland Sp. z o.o. | Bulgaria EOOD |
|---|---|---|
| Corporate income tax | 19% (9% small-taxpayer rate under conditions) | 10% flat |
| Dividend withholding tax | 19% | 5% |
| Combined burden on EUR 100 distributed profit (standard rates) | ~34.4% | 14.5% |
| Solidarity levy (danina solidarnosciowa) | 4% on personal income above PLN 1,000,000 | None |
| Social security for the owner-manager | ZUS on salary/dividend exemptions vary | Capped base, far lower absolute cost |
| Minimum share capital | PLN 5,000 (~EUR 1,150) | BGN 2 (~EUR 1) |
| VAT standard rate | 23% | 20% |
The 9% small-taxpayer CIT applies only to companies with revenue under EUR 2 million that meet shareholder and start-up conditions, and dividends are still taxed at 19%. Even under the 9% CIT, the combined burden lands around 26.4% — nearly double Bulgaria's 14.5%.
Polish Sp. z o.o. (standard 19% CIT):
Bulgarian EOOD:
Difference per EUR 150,000 of profit: roughly EUR 29,800 a year staying with the founder. Run your own numbers on our Bulgaria vs your country tax calculator.
Poland taxes companies whose place of effective management is in Poland as Polish tax residents, regardless of where they are registered. Polish CFC rules can also attribute profits of a controlled foreign company in a low-tax jurisdiction to a Polish resident shareholder.
A Bulgarian EOOD only works if it is real:
Founders who genuinely relocate to Bulgaria also leave Polish personal tax residency behind, subject to the centre-of-interests test. That is the clean version of this structure.
A Sp. z o.o. takes 2-6 weeks and PLN 5,000 minimum capital. A Bulgarian EOOD is registered in about 5 business days fully remotely with BGN 2 of capital. Full cost breakdown in our Bulgaria company formation cost guide and the step-by-step Bulgaria company formation timeline 2026.
Yes, when the Bulgarian company has real substance and either the founder relocates or management genuinely happens in Bulgaria. Simply re-domiciling on paper while continuing to run everything from Poland triggers Polish effective-management and CFC rules.
No. Even at 9% CIT plus 19% dividend tax the combined burden is about 26.4%, versus 14.5% in Bulgaria — and the 9% rate has eligibility conditions many companies fail.
It applies to personal income above PLN 1,000,000 and is another layer Bulgaria simply does not have. High-earning Polish founders face combined marginal rates well above 40%.
Yes. A Bulgarian company invoices Polish clients normally as intra-EU B2B services, usually reverse-charge for VAT. See our Bulgaria VAT registration guide.
Poland is a strong economy with a heavy tax stack for profitable service companies. Bulgaria offers the lowest combined corporate-plus-dividend burden in the EU at 14.5%, provided the structure is real. If you want numbers for your specific situation, book a free consultation or compare more pairs on our jurisdiction comparison hub.
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