Bulgaria’s National Assembly is reviewing the Bill on Amendments and Supplements to the Corporate Income Taxation Law and the Bill on Amendments and Supplements to the Value Added Tax Law, both submitted on 5 November 2026. The bills largely follow the drafts put out for consultation earlier, with a few notable changes.
Bulgaria’s National Assembly is reviewing the Bill on Amendments and Supplements to the Corporate Income Taxation Law and the Bill on Amendments and Supplements to the Value Added Tax Law, both submitted on 5 November 2026. The bills largely follow the drafts put out for consultation earlier, with a few changes.
Corporate tax
windfall tax on excess profits
The corporate income tax bill proposes a one-off 33% windfall tax on excess profits for the 2027 financial year. It targets banks, insurance companies, telecoms operators, large food retailers and quick loan providers.
Taxpayers could reduce the calculated tax due by up to 30%, provided the reduced amount is reinvested by the end of 2030. Qualifying reinvestment includes increasing primary capital, acquiring new tangible or intangible assets for the core business, or buying EU/EEA government bonds, subject to certain conditions.
Global minimum taxation
The corporate income tax bill also amends the Tax-Insurable Procedural Code to implement global minimum taxation rules for multinational groups under the OECD/G20 inclusive framework. It incorporates the Side-by-Side Package and specific safe harbour provisions.
The bill sets out administrative penalties, using a reference period from 2020 to 2025 to account for disruptions such as the COVID-19 pandemic and the energy crisis. It also covers administrative procedures, reporting deadlines and tax rates, including monthly advance payments and declarations required by January 2027.
VAT registration threshold
The VAT bill no longer proposes raising the mandatory registration threshold from EUR 51,130 to EUR 75,000 from 1 January 2027. The increase would instead come in stages:
- EUR 60,000 from 1 January 2027;
- EUR 70,000 from 1 January 2028; and
- EUR 75,000 from 1 January 2029.
The bill also updates VAT registration and deregistration procedures in line with Directive 2020/285 on special schemes for small enterprises, which allows national exemption thresholds of up to EUR 85,000. It refines the rules for taxable supplies related to land, buildings and sole traders.
E-invoicing timeline
The bill introduces mandatory structured electronic invoicing (e-invoicing) and real-time or near real-time digital reporting for domestic business-to-business (B2B) transactions. The requirements also cover business-to-government (B2G) transactions.
Under the original plan, e-invoicing would apply from 1 January 2028, with penalties from 1 July 2028. The revised proposal sets a mandatory test environment for businesses from 1 January 2028 to 30 June 2028, with penalties applying from 1 January 2029.
The bill aligns Bulgarian law with Directive 2014/55/EU and Directive (EU) 2025/516 under the “VAT in the Digital Age” (ViDA) framework. It establishes a National Portal for Structured Electronic Invoicing managed by the National Revenue Agency. Draft tax returns would be generated automatically from collected e-invoices and customs declarations.
Other VAT amendments
The bill converts monetary thresholds, fixed statutory amounts and administrative fines in the VAT Act from Bulgarian levs (BGN) to euros (EUR).
It applies a zero VAT rate or exemption to supplies, intra-Community acquisitions and imports of defence products. This integrates Council Regulation (EU) 2025/1106, which establishes the “Security Action for Europe” instrument to strengthen European defence production.
Fines and administrative penalties that had not changed since 2007 would be recalibrated to restore their preventive effect. Enforcement measures, such as sealing commercial premises, would be adjusted to comply with Case C-733/23 of the Court of Justice of the European Union and the ne bis in idem principle.
Expected budget impact
The bill was submitted following Decision No. 843 of the Council of Ministers. Real-time digital reporting and anti-fraud measures are projected to add EUR 350 million to the 2028 state budget.
