A Bulgarian EOOD gives a Belarusian founder an EU company for EUR 1 of capital and 10% corporate tax. Bulgarian company law has no rule against Belarusian owners. As with Russia, what changes the picture is that Bulgaria is in the EU: European sanctions on Belarus apply directly at the bank, and the bank visit requires a Schengen visa.
On the Belarusian side, the rules are lighter than in Russia: no controlled foreign company regime, but currency contract registration and a dividend declaration.
What Bulgaria asks of a Belarusian founder
- Nothing specific in company law: one owner, one manager, EUR 1 of capital.
- Documents by apostille: Belarus and Bulgaria are both parties to the Apostille Convention; add a certified Bulgarian translation.
- Sanctions screening by the lawyer and the bank.
- A Schengen visa for the bank visit.
The steps are in how to register a company in Bulgaria.
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EU sanctions: the deposit ceiling
Since March 2022, EU banks may not accept deposits from Belarusian nationals or residents, or from entities established in Belarus, once the total exceeds EUR 100,000 per bank.
| Situation | Deposit ceiling |
|---|---|
| Belarusian citizen living in Belarus | Applies |
| Belarusian citizen with an EU, EEA or Swiss residence permit | Does not apply |
| Dual national with EU, EEA or Swiss citizenship | Does not apply |
| Deposits needed for permitted trade between the EU and Belarus | Exempted |
Advisers report that the rule was later extended to companies outside the EU more than 50% controlled by Belarusians. Banks add their own policy: expect detailed questions on counterparties and the source of funds, and refusals for transfers from sanctioned Belarusian banks. See the bank account guide.
- 1Are you on an EU sanctions list?Then no account is possible
- 2Do you hold EU, EEA or Swiss citizenship?Then the ceiling does not apply
- 3Do you hold a residence permit there?Then the ceiling does not apply
- 4OtherwiseDeposits capped at EUR 100,000 per bank
Belarus has no CFC rules
The Belarus Tax Code contains no regime that taxes a resident on the undistributed profit of a foreign company.
- Profit kept in the EOOD is taxed at 10% in Bulgaria and not in Belarus.
- Tax arises in Belarus when the dividend is paid.
- The stake must still be reported: a participation in a foreign organisation is notified to the tax office within ten working days.
This is the main difference with Russian founders; see the guide for founders from Russia.
How the dividend is taxed
| On 100 of Bulgarian profit | Individual owner | Belarusian company as owner |
|---|---|---|
| Bulgarian corporate tax, 10% | 10.00 | 10.00 |
| Dividend paid | 90.00 | 90.00 |
| Bulgarian withholding, 5% | 4.50 | 4.50 |
| Belarusian tax before credit | 11.70 at 13% | 10.80 at 12% |
| Credit for the Bulgarian withholding | 4.50 | 4.50 |
| Left after all tax | 78.30 | 79.20 |
- Residence: more than 183 days in Belarus in the calendar year.
- Rate: 13% on dividends, 25% above BYN 350,000 in the tax period.
- Declaration: foreign income declared by 31 March of the following year.
- Credit: foreign tax is credited, except for income from the presidential list of offshore zones; check that Bulgaria is not on the current list.
- Treaty: Belarus and Bulgaria have a tax treaty; Bulgaria's own 5% already applies to dividends.
Moving the capital out of Belarus
- Register the currency contract before the first transfer when it exceeds 2,000 base units for an individual or 4,000 for a company. A contribution to the capital of a foreign company is on the list.
- Your Belarusian bank can refuse an operation under an unregistered contract.
- EUR 1 of capital keeps the first transfer small; funding operations is where registration matters.
Visa and residence
Belarusian citizens need a Schengen visa for the bank visit and a D visa to live in Bulgaria as manager. A Bulgarian residence permit also lifts the EU deposit ceiling. See non-resident founders.
The bottom line
For a Belarusian founder, a Bulgarian EOOD is simpler on the tax side than for a Russian: no CFC rules, 10% in Bulgaria, 13% on dividends at home with a credit, about 78 left from 100 of profit. The constraints are EU sanctions at the bank, with a EUR 100,000 deposit ceiling unless you hold an EU residence permit, and the Belarusian currency contract registration.
corpsec registers the EOOD and provides its registered address; sanctions screening is done by the lawyer and the bank. See the Bulgaria formation service, or compare with a Georgian company for Belarusian founders.
Frequently asked questions
Can a Belarusian citizen open a company in Bulgaria?
Yes. Bulgarian company law has no restriction on Belarusian owners or managers, unless they are on an EU sanctions list.
Can Belarusians open a bank account in Bulgaria?
Yes, but EU rules cap deposits from Belarusian nationals and residents at EUR 100,000 per bank, unless they hold EU, EEA or Swiss citizenship or a residence permit there.
Does Belarus tax profit kept in a Bulgarian company?
No. Belarus has no controlled foreign company rules; tax arises when the dividend is paid.
How are Bulgarian dividends taxed in Belarus?
At 13%, or 25% above BYN 350,000, with a credit for the Bulgarian 5%. A Belarusian company pays 12%.
Do Belarusians need a visa for Bulgaria?
Yes. Bulgaria is a full Schengen member, so a Schengen visa is needed for visits and a D visa to live there.
Sources
- Council Regulation (EU) 2022/398, inserting Article 1u into Regulation (EC) No 765/2006: no deposits above EUR 100,000 per credit institution from Belarusian nationals, residents or entities, with exemptions for EU, EEA and Swiss nationals and residence permit holders
- Council Decision (CFSP) 2022/399, Article 2u: the same deposit restriction in the Council decision
- Tax Code of Belarus, Special Part, consolidated text: dividend rates, the 31 March declaration, the foreign tax credit, and no chapter on controlled foreign companies
- National Bank of Belarus, Instruction No. 37 of 12 February 2021 on registration of currency contracts, with the 2022 and 2024 amendments: thresholds of 2,000 and 4,000 base units, capital contributions abroad listed
- Deloitte, Bulgaria Highlights 2026: 10% corporate income tax and 5% withholding on dividends paid to non-residents
Read on 26 October 2026: Regulation (EU) 2022/398 in a consolidated reproduction and Decision 2022/399 on EUR-Lex, and Deloitte's Bulgaria Highlights 2026. Read on 5 October 2026 for this series: the Belarus Tax Code including the amendments of 30 December 2025, Law No. 226-Z and National Bank Instruction No. 37. Later EU amendments extending the deposit rule to third-country entities controlled by Belarusians are reported by advisers and were not read. The Belarus and Bulgaria treaty is listed by PwC, but its text and rates were not found; Bulgaria's domestic 5% on dividends is shown. We did not find an EU rule on reporting transfers for Belarusian-owned companies like the Russian one. Our calculations assume the 13% rate on dividends and a full credit for the Bulgarian withholding. This is not legal or tax advice.
