Working from Bulgaria as a Germany resident

At a glance

What you would actually pay

The headline rates, and the qualifier that has to travel with them. Every figure comes from Bulgaria's own cross-checked rules, not from an estimate.

Income tax

A genuine flat 10%. No brackets, no municipal surcharge.

Corporate tax

Flat 10%, and an EOOD forms on EUR 1 of capital.

Getting profit out

5% to you personally, 0% to an EU or EEA parent company.

Honest all-in

About 14.5% all-in through an EOOD, and the low contribution ceiling is what really makes it cheap at a high income.

Rule coverage

What the rules say about Bulgaria

The rules below are the ones most likely to shape a stay in Bulgaria, in plain words and with the source behind each one. Your own report tells you which of them apply to you.

1. Significant issueMoving your company

   An EOOD run from the Netherlands is a Dutch company too, and the treaty will not rescue it

   This is the corridor's biggest and most under-warned failure mode. Bulgaria treats an EOOD as Bulgarian-resident purely because it is incorporated and seated there, it does not apply a management test. The Netherlands determines corporate residence under art. 4 AWR on the facts, principally where actual management (feitelijke leiding) is exercised, if the sole director sits in Amsterdam taking every real decision there, the EOOD is ALSO a Dutch resident company, liable to Dutch corporate tax on its worldwide profit at 19 to 25.8 percent. The treaty does not break this tie in the taxpayer's favour, Article 4(5) provides that for a dual-resident company the competent authorities shall endeavour to determine residence by mutual agreement having regard to effective management, incorporation and other factors, and in the absence of such agreement the company is NOT entitled to any treaty relief except non-discrimination and mutual agreement procedure articles. So a badly-run structure is not taxed by the better of two countries, it is taxed by both and relieved by neither, pending a mutual agreement procedure the taxpayer must fund and wait years for. On the positive side, Bulgaria's 10 percent statutory corporate rate sits one point above the Dutch low-tax list threshold of 9 percent or less, and Bulgaria's EU membership keeps it off the list entirely, meaning no Dutch conditional withholding tax at 25.8 percent applies to interest, royalties or dividends flowing to a Bulgarian entity, and Bulgaria sits outside the Dutch CFC measure's designated-jurisdiction list, this is a genuine structural point in the corridor's favour, though it rests on inference from the definition rather than a line-by-line read of the current year's list, and a future Bulgarian rate cut below 10 percent would flip it.

2. Significant issueTax residency

   Past 183 days in a rolling 12 months, both arrival and departure days count

   ZDDFL art. 4(2)-(3) fixes the 183-day test on a rolling twelve month window, not a calendar year, though residency itself is treated as attaching to the calendar year in which the 183 days are exceeded. Two mechanical rules change the arithmetic in ways that catch people out: the day of arrival and the day of departure each count separately as a day of presence, so a Friday-in, Sunday-out weekend burns three days, not one, and because Bulgaria has been a full Schengen member since 1 January 2025 there are no systematic entry or exit stamps recording your movements, so you must keep your own evidence, flight records, card transactions, lease and utility records, to prove your day count either way. Once resident, you are taxed on worldwide income at the flat 10 percent rate rather than only on Bulgarian-source income.

3. Needs checkingSocial security

   Bulgaria never signed the EU telework Framework Agreement, the 49.9 percent rule you may have heard of does not apply here

   The Framework Agreement on the application of Article 16(1) of Regulation 883/2004 for habitual cross-border telework is deposited with the Belgian FPS Social Security and, as retrieved, lists 23 signatory states including the Netherlands, but Bulgaria is not on that list, and neither is Denmark, Greece, Cyprus, Hungary, Romania, Latvia or Iceland. That agreement is what lets an employee keep home-country social security while teleworking up to 49.9 percent of their time from a signatory state. Because the agreement requires BOTH the employer's state and the state of residence to be signatories, and Bulgaria is not one, there is no A1 available under the Framework Agreement on the Netherlands to Bulgaria corridor, full stop, regardless of how the Dutch side of the arrangement looks. Any answer about this corridor that mentions the 49.9 percent Framework Agreement threshold is wrong for Bulgaria and should be treated as a red flag that the source has not checked the actual signatory list.

4. Needs checkingPersonal income tax

   Director's fees from your Bulgarian company get a Dutch tax credit, not an exemption, the Bulgarian rate becomes a floor

   NL-BG treaty Article 15 provides that director's fees derived by a resident of one state as a board member of a company resident in the other state may be taxed in that other state. Article 22 then splits relief into two baskets read from the treaty text: paragraph 2 (exemption with progression) covers ordinary employment income under Article 14(1) among others, while paragraph 4 (credit only) covers Article 10(2,10) dividends, Article 13(6) share appreciation, and crucially Article 15 director's fees, plus pensions under Article 17(5) in part. Article 15 sits in the CREDIT basket. So if you remain a Netherlands resident and draw a director's fee from your Bulgarian EOOD, you pay Bulgarian tax on it first (10 percent, or ДУК employee treatment if a management contract with remuneration exists), and the Netherlands then taxes the same fee at full Dutch box 1 rates with only a credit for the Bulgarian tax paid. The Bulgarian rate does not save you anything on this income stream, it becomes a floor topped up to the Dutch rate, not a final saving. Contrast ordinary employment income under Article 14(1), which sits in the exemption basket and genuinely is exempted with progression in the Netherlands.

5. Needs checkingImmigration and visa

   The LNCH personal number is the gate on everything else, get it first

   On registration with the Migration Directorate you are assigned an LNCH (Личен номер на чужденец), a ten-digit personal number that functions as a foreigner's equivalent of the Bulgarian EGN. Without it you cannot open a bank account, register with the NRA, register as a self-insured person, be entered as a company manager in the Commercial Register, or enrol with the national health fund. Almost everything else in a Bulgarian relocation, tax registration, company formation, health cover, depends on this single administrative artefact existing first, so it belongs at the very start of your checklist, not somewhere in the middle.

6. Needs checkingLeaving home: exit tax and ties

   The Dutch exit tax deferral is automatic and free, but it is lifelong, not five or ten years

   On emigration the Netherlands imposes a conserverende aanslag (conservatory assessment) on four things, a substantial interest (aanmerkelijk belang) treated as a deemed disposal, Dutch-built pension, lijfrente annuity, and kapitaalverzekering or comparable eigen woning capital products. Deferral is automatic on emigration to an EU or EEA state, and Bulgaria qualifies, no application and no security required, that part is genuinely good news. This follows Dutch TAX RESIDENCE, not Dutch nationality, so it applies equally to a German or Italian national who was Dutch tax resident and now leaves. But the old five or ten-year story does not survive contact with current law: the ten-year remission rule for the substantial-interest assessment was abolished for emigrations after 15 September 2015, 15:15, for those the deferral is lifelong with no remission at all, the ten-year remission still applies to pension, annuity and eigen-woning capital insurance if their rules are observed throughout. The deferral is withdrawn, pro rata, on realisation events, selling the shares, distributing a dividend, or winding up the company, this is exactly what catches a founder who moves to Bulgaria and then pays themselves accumulated BV reserves at the low 5 percent Bulgarian dividend rate, the Dutch deferral unwinds on that same distribution.

What tends to surprise people here

• No telework framework agreement, social security flips at 25 percent of working time
• A Bulgarian company managed from the Netherlands is simply a Dutch taxpayer
• Bulgaria sits one point above the Dutch low-tax blacklist line, so structures get extra scrutiny

Tax treaty between Germany and Bulgaria