Holding Company in Bulgaria
What the law requires
- A holding can be an AD, an OOD or a partnership limited by shares.
- Its purpose is to take part in other companies or in their management.
- A company counts as a holding’s subsidiary when the holding owns at least 25% of it, or can appoint more than half of its board.
- At least 25% of the holding’s capital must be invested in its subsidiaries.
Source: Commercial law in Bulgaria: Holding companies, Commerce Act articles 277–2801
What a holding may and may not do
| May | May not |
|---|---|
| Invest in shares of Bulgarian and foreign companies | Join partnerships that are not legal persons |
| Buy bonds to gain control of a company | Acquire licences its subsidiaries will not use |
| Manage patents among its subsidiaries | Buy real estate it does not need for itself |
| Lend to its subsidiaries and borrow from them | — |
Source: Commercial law in Bulgaria: Holding companies, Commerce Act articles 277–2801
Tax
- Dividends received from Bulgarian companies and from companies resident in the EU or EEA are excluded from taxable profit.
- Dividends paid to a parent in the EU or EEA carry no withholding tax; others pay 5% or a lower treaty rate.
- Gains on shares sold on a regulated market in the EU or EEA are exempt; other gains are taxed at 10%.
- There is no special holding company regime and no participation exemption beyond these rules.
- Controlled foreign company rules can tax low-taxed foreign subsidiaries without real activity.
Source: Deloitte: International Tax, Bulgaria Highlights 2026; PwC Worldwide Tax Summaries: Bulgaria, corporate income determination2,3
Frequently Asked Questions
What is a holding company in Bulgaria?
A Bulgarian holding company can be a joint-stock company, a limited liability company or a partnership limited by shares. Its purpose is to take part in other companies or in their management.
What stake makes a company a subsidiary of a Bulgarian holding company?
A company is a subsidiary if the holding company owns at least 25% of it or can appoint more than half of its board. At least 25% of the holding company’s capital must be invested in its subsidiaries.
Are dividends received by a Bulgarian holding company taxable?
Dividends received by a Bulgarian holding company from Bulgarian companies and companies resident in the EU or EEA are excluded from taxable profit. This means the tax rate on those dividends is 0%.
What tax does a holding company pay on other profits in Bulgaria?
A Bulgarian holding company pays 10% corporate tax on other profits, as there is no special holding company tax regime. Gains on shares sold on a regulated market in the EU or EEA are exempt, while other share gains are taxed at 10%.
Is withholding tax charged on dividends paid by a Bulgarian holding company?
Dividends paid by a Bulgarian holding company to a parent company resident in the EU or EEA are not subject to withholding tax. Other recipients face 5% withholding tax, or a lower rate under an applicable treaty.
Sources
- Commercial law in Bulgaria: Holding companies, Commerce Act articles 277–280
- Deloitte: International Tax, Bulgaria Highlights 2026 (PDF)
- PwC Worldwide Tax Summaries: Bulgaria, corporate income determination
Figures checked 13 October 2026. Prepared by InvestBulgaria for general information. It is not investment, tax or legal advice; please confirm details with a qualified adviser before acting.
