Global Minimum Tax Developments in Bulgaria
Bulgaria has introduced key updates to its implementation of the 15% global minimum tax, impacting large multinational groups from 1 January 2024. Proposed amendments to the Corporate Income Tax Act will further refine local tax rules and timelines, requiring proactive compliance by international businesses.
Minimum Tax Scope and Who is Affected
The legislation applies to multinational groups with consolidated revenues exceeding €750 million in at least two of the past four fiscal years. Bulgarian companies and permanent establishments falling within this threshold are now subject to an additional local minimum surtax of up to 15%, following Bulgaria's decision to retain taxing rights domestically.
Proposed Amendments to the Corporate Income Tax Act
In February 2025, the Ministry of Finance introduced a draft law to adjust the current tax rules. Key proposed amendments include:
- Accounting Framework Alignment:
The calculation of the additional tax will depend on the applicable accounting standards within the group:- Bulgarian GAAP where applicable.
- IFRS when followed locally.
- Consolidated group standards (e.g., US GAAP, UK GAAP) where relevant.
- Revised Tax Periods:
- For Bulgarian GAAP and IFRS cases, the tax will now apply on a calendar-year basis.
- For groups using consolidated standards, the tax will continue to follow the group's accounting period.
Filing and Payment Timeline Shift
Groups with non-calendar fiscal years under Bulgarian GAAP or IFRS will now need to file and settle the 15% surtax for the full year 2024 by 30 June 2026, altering previous rules requiring partial payments within 18 months of the group's financial year-end.
Eurofast's Take – Supporting Your Global Compliance
Eurofast Bulgaria is actively assisting multinational clients to navigate these new requirements. Our specialists provide tailored advice on tax alignment, reporting obligations, and local compliance strategies to ensure a smooth transition under Bulgaria's evolving tax landscape.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
