In Bulgaria, the taxation of company dividends is subject to specific rules and rates depending on the residency and type of the recipient. Here's an overview of how dividends are taxed in Bulgaria:

1. Dividends Paid to Domestic Shareholders

Individual Shareholders

• Personal Income Tax (PIT): Dividends paid to individual residents are subject to a final withholding tax of 5%. This tax is withheld at the source by the paying company.

Corporate Shareholders

• Corporate Income Tax (CIT): Dividends received by Bulgarian resident companies from other Bulgarian companies are generally exempt from corporate income tax. This exemption is in place to avoid double taxation of profits within Bulgaria.

2. Dividends Paid to Non-Resident Shareholders

Individual Shareholders

• Withholding Tax: Dividends paid to non-resident individuals are subject to a withholding tax of 5%. The tax is withheld at the source by the Bulgarian company paying the dividend.

Corporate Shareholders

• Withholding Tax: Dividends paid to non-resident companies are also subject to a withholding tax of 5%. However, this rate can be reduced or eliminated under applicable double tax treaties or the EU Parent-Subsidiary Directive.

3. Double Taxation Agreements (DTAs)

Bulgaria has an extensive network of double tax treaties with numerous countries. These treaties often provide for reduced withholding tax rates on dividends, or in some cases, complete exemption. The specific rates and conditions depend on the terms of the applicable treaty.

4. EU Parent-Subsidiary Directive

Under the EU Parent-Subsidiary Directive, dividends paid by a Bulgarian subsidiary to an EU parent company are exempt from withholding tax, provided the parent company holds at least 10% of the subsidiary’s capital for a minimum uninterrupted period of one year.

Summary of Key Points

• Resident Individuals: 5% final withholding tax on dividends.
• Resident Companies: Dividends received are generally exempt from corporate income tax.
• Non-Resident Individuals: 5% withholding tax on dividends.
• Non-Resident Companies: 5% withholding tax on dividends, subject to reduction or exemption under double tax treaties or the EU Parent-Subsidiary Directive.
• Double Tax Treaties: May provide reduced tax rates or exemptions.
• EU Parent-Subsidiary Directive: Exempts qualifying dividends from withholding tax.

Practical Considerations

• Tax Planning: Businesses and investors should consider both domestic tax laws and international treaties to optimize their tax positions.
• Compliance: Proper documentation and adherence to regulatory requirements are essential to benefit from exemptions and reduced tax rates.
• Professional Advice: Consulting with tax advisors or legal experts familiar with Bulgarian and international tax laws can help navigate the complexities and ensure compliance.

By understanding the dividend taxation rules in Bulgaria and leveraging international agreements, businesses and investors can effectively manage their tax obligations and take advantage of available benefits.