2026.04.12
Bulgarian holding companies after the 2026 corporate tax revision
What the new participation-exemption thresholds mean for EU and non-EU groups using a BG topco.
→ Read// PRACTICE AREA
Tax
Structuring, transfer pricing, and cross-border tax counsel for funds, holdings, and operating groups.
// OVERVIEW
Tax work spans BG corporate tax (10% flat), EU-wide indirect tax, and the substance-and-PE questions that decide where profit actually lands. We build structures that survive ATAD, BEPS, and the next round of EU directives — not just the current one.
We advise funds, family offices, and operating groups. Engagements are scoped against a written tax memo so the client knows the basis of every position before a return is filed or a structure is funded.
// WHAT WE DO
Specific work, named clearly.
01
Holding structure design
BG, Estonia, Malta, Cyprus, and Luxembourg holding analyses with substance plans.
02
Transfer pricing documentation
Master file, local file, and benchmarking for BG and EU group requirements.
03
VAT & cross-border indirect tax
Triangulation, OSS/IOSS, reverse charge, and customs interface advisory.
04
Tax residency & PE analysis
Place-of-effective-management reviews and permanent establishment risk mapping.
05
Fund & investment vehicle taxation
AIF, SICAV, and partnership structuring with investor tax reporting.
06
Crypto & digital asset tax
Trading, staking, and treasury treatment under BG and EU MiCA-aligned regimes.
07
Tax controversy & NAP disputes
Audit defence, appeals, and litigation before the National Revenue Agency and courts.
// HOW WE WORK
Diagnose. Scope. Deliver. Review.
01
Diagnose
We map the matter, surface the real risk, and define what success looks like before quoting.
02
Scope
Fixed fee or capped retainer with named deliverables, owners, and dates — in writing.
03
Deliver
Work product through the secure portal. Status visible at all times. No black box.
04
Review
Post-matter debrief, lessons captured, and renewal of the engagement only if it earns it.
// FAQ
Frequently asked.
// RELATED
Related insights.
2026.03.28
Dual-use export licensing: the EU 2021/821 walkthrough
A practical map of when a licence is required, who issues it, and how long approvals actually take.
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Trademark enforcement in the EU: a 2026 cost-benefit view
When EUIPO opposition beats litigation, and when it doesn't — with real numbers.
→ ReadHave a matter in Tax?
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