Bulgaria: Key Tax Developments in Bulgaria for 2026: Legislative Amendments and Strategic Hot Topics

The Bulgarian tax framework in 2026 combines legislative continuity with significant structural developments. While no major amendments were introduced in the Corporate Income Tax Act or the Personal Income Tax Act, important changes were made in VAT legislation. At the same time, the implementation of the EU global minimum tax, the completion of the OECD tax review, and the adoption of the euro mark 2026 as a year of systemic transition.

As of 1 January 2026, the mandatory VAT registration threshold is set at EUR 51,130. Taxable turnover is now calculated on a calendar-year basis rather than over a rolling 12-month period. Non-registered persons begin monitoring turnover from EUR 0 at the start of each year.

Directive (EU) 2020/285 introduced special VAT regimes for small enterprises. Eligible businesses may supply goods and services across Member States without VAT registration in each jurisdiction, provided national thresholds and a cumulative EU-wide turnover of EUR 100,000 are not exceeded.

Directive (EU) 2022/542 introduced updated place-of-supply rules for services granting virtual access to live-streamed events. These rules affect conferences, seminars, and educational activities conducted online and may impact VAT registration obligations.

Regulation (EU) 2023/2831 aligned the special VAT regime for imports under investment projects with updated de minimis state aid rules, strengthening legal certainty for investors.

As of 2026, Bulgaria implemented the EU global minimum tax (Pillar Two), applicable to multinational enterprise groups with consolidated annual revenues exceeding EUR 750 million. Although the domestic corporate tax rate remains 10%, affected groups may be subject to a top-up tax where the effective tax rate falls below 15% under the GloBE rules.

Bulgaria is also in the final stage of its accession to the OECD, with the tax chapter review completed in October 2025. A new ordinance was adopted to reflect updates to the OECD Transfer Pricing Guidelines and amendments to the Tax and Social Security Procedure Code. In addition, amendments were introduced to the Bulgarian commentary on Article 12 (Royalties) of the national Model Tax Convention, reflecting an updated interpretative approach in cross-border taxation.

Finally, as of 1 January 2026, Bulgaria adopted the euro as its national currency. All tax reporting, accounting records, and invoices are now denominated in euros. The transition required technical adjustments but did not change tax rates.

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