Bulgaria: Post-Euro Adoption Tax Amendments and Pillar Two Clarifications
Following the adoption of the euro, in force as of 1 January 2026, the Bulgarian authorities have introduced tax amendments aimed at aligning the corporate income tax framework with the new currency environment and clarifying certain application aspects of the global minimum tax regime (Pillar Two).
The draft law primarily provides for technical and formal amendments to the tax legislation, including the replacement of references to the Bulgarian lev with the euro and updates to the exchange rate rules, now based on the official rates published by the Bulgarian National Bank. These changes are intended to ensure the correct determination of tax bases and tax amounts under the new monetary framework.
With regard to Pillar Two, the proposal introduces editorial and technical clarifications concerning the top-up tax and the domestic top-up tax applicable to multinational groups and large domestic groups, clarifying the scope of application of the regime, the coordination between the different tax instruments and certain key concepts, in line with the OECD Model Rules.
In parallel, the Bulgarian tax authorities have announced operational initiatives to support affected taxpayers, including a dedicated section on their official website and updated forms required for the management of double tax treaties, in force as of 1 January 2026.