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6 September 20264 min read

Sweden AB vs Bulgaria EOOD: Real Tax Comparison for Swedish Founders (2026)

Swedish AB profits face 20.6% corporate tax plus 3:12 rules on dividends, and salary can reach 55%. Bulgaria totals 14.5%. The 2026 numbers, exit rules and what has to move.

Sweden AB vs Bulgaria EOOD: Real Tax Comparison for Swedish Founders (2026)

Sweden's corporate rate looks competitive at 20.6%. The problem for owner-managers is everything that happens after the company has paid it: the 3:12 closely held company rules, the 30 to 57% band on dividends above the allowance, and payroll charges of just over 31% on salary. This guide puts the 2026 numbers next to a Bulgarian EOOD.

The 2026 headline numbers

ItemSweden ABBulgaria EOOD
Corporate income tax20.6%10%
Dividends within the 3:12 allowance20%5%
Dividends above the allowanceUp to 57% as employment income5%
Employer social charges on salary31.42%Capped contribution base
Combined on distributed profit, typical37% to 55%14.5%
Minimum share capitalSEK 25,000BGN 2 (about EUR 1)
Standard VAT25%20%

On EUR 200,000 of profit distributed in full, a Swedish founder past the allowance can easily land above EUR 80,000 in combined tax. Bulgaria costs roughly EUR 29,000.

The 3:12 rules in one paragraph

For a closely held Swedish company, a portion of your dividend is taxed at a flat 20%. That portion is the gransbelopp, set either by a simplified standard amount or by a salary-based rule that requires you and your company to pay substantial wages. Anything above it is taxed as employment income at marginal rates. Founders with high profit and low headcount hit the ceiling quickly, which is exactly the profile of a solo consultant or software business.

Bulgaria has no equivalent tiering. Company profit is taxed at 10%, distributions at 5%, regardless of how much you take. The dividend tax guide explains the payout procedure and documentation.

Salary versus dividends

In Sweden, salary carries 31.42% employer charges plus municipal and state income tax, but it also builds the salary-based allowance under 3:12. The optimisation dance is real work every year.

In Bulgaria, a manager's contract with a moderate salary costs little because contributions sit on a capped base, and it produces clean evidence of local management. Dividends then carry a flat 5%. See the payroll and employer cost guide for the 2026 bases.

Leaving Sweden: the ten-year rule

Sweden claims taxing rights on capital gains from Swedish shares for up to ten years after emigration, subject to treaty relief. Several treaties reduce that period. Selling a Swedish AB shortly after moving is therefore not a clean exit, and the order of events matters: establish the new residence, understand the treaty article that applies, then decide about the old company.

You may also stay Swedish tax resident under the vasentlig anknytning test if you keep a home, family or business ties in Sweden, even after physically leaving.

Place of effective management

A Bulgarian company run day to day from Stockholm is a Swedish tax resident company under Swedish rules and the treaty tie-breaker. Real substance means decisions taken in Bulgaria, a genuine registered address, a Bulgarian business bank account, local accounting, and contracts issued by the Bulgarian entity.

Invoicing Swedish clients

B2B services to Swedish VAT-registered clients are reverse charged once you hold a VIES-validated Bulgarian VAT number. B2C sales go through OSS above the EUR 10,000 pan-EU threshold. The VAT registration guide covers thresholds and monthly filings.

Formation, timeline and running costs

  • Formation from EUR 399, typically five business days
  • Remote incorporation via notarised and apostilled power of attorney
  • Registered address from EUR 200 a year
  • Accounting from EUR 50 a month
  • Financial statements and corporate tax return due 30 June

The documents checklist shows what to prepare, the filing calendar lists deadlines.

Frequently asked questions

Is 20.6% not already low enough?

The corporate rate is. The total cost of getting money into your own hands is not, because 3:12 pushes surplus dividends into employment income rates. Compare total burden, not headline rates.

Can I keep the AB and run new work through Bulgaria?

Yes, provided the split is commercially real and any services between the companies are priced at arm's length. Swedish CFC rules must also be checked where the AB or you personally control the Bulgarian company while remaining Swedish resident.

Do Swedish CFC rules catch Bulgaria?

Bulgaria's 10% rate sits close to the CFC comparison threshold, and Bulgaria appears on Sweden's list treatment for many activities, but genuine business activity conducted in Bulgaria with real substance is the deciding factor. Get this reviewed before relying on the structure while remaining Swedish resident.

What about social security?

If you relocate and work exclusively through the Bulgarian company, Bulgarian social security applies under the EU coordination rules. Multi-country work needs an A1 assessment.

How much profit makes it worthwhile?

Above roughly EUR 60,000 of annual distributable profit the annual saving clearly exceeds the running cost of a compliant Bulgarian structure.

Next step

Run the numbers in the tax calculator, compare options on the EU tax comparison page, then book a free consultation.

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