Double Tax Treaties in Bulgaria

What a treaty does

• Lower tax on income paid abroad. Without a treaty, Bulgaria withholds 5% on dividends and 10% on interest, royalties, technical services and certain capital gains paid to non-residents. A treaty can lower these rates.
• Residence. Where a person counts as resident in both countries, the treaty decides which one, and overrides the Bulgarian tests; see Tax Residency.
• Relief for residents. A Bulgarian resident’s foreign income is either exempt in Bulgaria or taxed with a credit for the foreign tax, depending on the treaty.
• The Multilateral Instrument. The OECD convention entered into force for Bulgaria on 1 January 2023 and changes 64 of its treaties: for withholding taxes from 1 January 2023, for other taxes from 1 January 2024.

Source: PwC Worldwide Tax Summaries: Bulgaria, corporate, withholding taxes (reviewed 2 August 2026); PwC Worldwide Tax Summaries: Bulgaria, individual residence; National Revenue Agency: Avoiding double taxation of foreign income in 2025; National Revenue Agency: Multilateral Convention amending tax treaties^2,9,5,4

Within the EU no treaty is needed for some payments: dividends to companies resident in the EU or EEA, and interest and royalties to associated EU companies holding at least 25% for two years, are exempt from Bulgarian withholding tax; see Dividend Tax.²

The 71 treaty countries

Albania, Algeria, Armenia, Austria, Azerbaijan, Bahrain, Belarus, Belgium, Canada, China, Croatia, Cyprus, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Georgia, Germany, Greece, Hungary, India, Indonesia, Iran, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Kuwait, Latvia, Lebanon, Lithuania, Luxembourg, Malta, Moldova, Mongolia, Montenegro, Morocco, Netherlands, North Korea, North Macedonia, Norway, Pakistan, Poland, Portugal, Qatar, Romania, Russia, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, South Africa, South Korea, Spain, Sweden, Switzerland, Syria, Thailand, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam and Zimbabwe.¹

• Newest: the Netherlands (in force 31 July 2021, replacing the 1990 treaty), Pakistan (2020), Saudi Arabia (2018) and Romania (2016); a protocol to the German treaty entered into force on 13 December 2023.
• Andorra: a treaty was signed on 19 June 2026 and is not yet on the list of treaties in force.
• Russia: Russia suspended most of the treaty, Articles 5 to 22 and 24, from 8 August 2023.

Source: National Revenue Agency: List of double tax treaties; BTA: Bulgaria and Andorra sign a double taxation agreement (19 June 2026); Ministry of Finance of Russia: Status of Russia’s double tax treaties, 7 April 2025 (in Russian)^1,8,7

Main treaty rates

Source: PwC Worldwide Tax Summaries: Bulgaria, corporate, withholding taxes (reviewed 2 August 2026); National Revenue Agency: List of double tax treaties^2,1

Where two rates are shown, the lower one applies only in set cases, such as a minimum holding or payments to public bodies. PwC dates its summary of the treaty rates 1 January 2021, while noting later changes such as the new Dutch treaty; check the treaty and any protocol before relying on a rate.²

Claiming relief on income from Bulgaria

• Up to BGN 500,000 (€255,645.94) a year from one payer: no request to the tax authority is needed. The recipient gives the payer a certificate of tax residence and a declaration that it is the beneficial owner, and the payer withholds at the treaty rate.
• Above that amount: the recipient or its representative files a request with the National Revenue Agency first, with the certificate, the declaration, proof of who signed it, and the contracts and invoices. A ruling takes up to 60 days where the agency checks the case; for an ongoing contract one request is enough.
• Tax already withheld: a refund can be claimed with the same evidence; the agency decides within 30 days unless it orders an audit.
• The payer reports the income paid and the relief given by 31 March of the following year.

Source: National Revenue Agency: Applying double tax treaties; PwC Worldwide Tax Summaries: Bulgaria, corporate, withholding taxes (reviewed 2 August 2026)^3,2

A company counts as beneficial owner only if it can dispose of the income, decides how it is used and bears the risk of the activity behind it. Conduit companies, which hold the asset but have no real activity, staff or control of their own, do not qualify.²

Residents with foreign income

Bulgarian residents declare foreign income in the annual return due by 30 April and apply the method in the relevant treaty. The exemption method needs the income to have been taxable abroad under the treaty; a credit needs proof of the foreign tax paid, such as a withholding certificate, and is generally limited to the Bulgarian tax on the same income. A foreign tax authority may ask for a Bulgarian certificate of tax residence.^5,6