Bulgaria has promulgated a law extending the scope of its tax cooperation convention to cover Pillar Two top-up taxes, paving the way for the exchange of GloBE information with other jurisdictions.
Bulgaria published Decree No. 304 in the State Gazette on 18 September 2026, promulgating the Law on the Supplement to the Law on the Ratification of the Convention on Mutual Administrative Assistance in Tax Matters.
The amendment adds Pillar Two top-up taxes to the list of covered taxes under the Convention, enabling the country to meet its exchange obligations under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.
The law was adopted by the 52nd National Assembly on 10 September 2026 and signed into decree by President Iliana Iotova in Sofia on 14 September 2026, with Minister of Justice Nikolay Naydenov countersigning under the state seal. It took effect immediately upon promulgation in the State Gazette.
Under the amendment, Annex A of the Convention, titled “Existing taxes to which the Convention shall apply,” now lists three additional taxes following the existing entry for corporate income tax: the “primary supplementary tax,” the “secondary supplementary tax,” and the “national supplementary tax.” These correspond to Bulgaria’s domestic implementation of the Pillar Two top-up tax regime.
The Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2011 Protocol, provides the legal basis for exchange of information, assistance in tax collection, and other forms of cross-border cooperation among signatory states. By bringing its top-up taxes within the Convention’s scope, Bulgaria aligns its framework with international standards for administering the global minimum tax and facilitates the automatic exchange of GloBE information with treaty partners.
The measure was recorded in National Assembly Issue No. 86 of 18 September 2026, in the Official Section of the National Assembly gazette.
