Nigeria
Bulgaria
A Bulgarian EOOD gives a Nigerian founder an EU company for EUR 1 of capital, 10% corporate tax and a 5% dividend tax. Since 1 January 2026, the Nigeria Tax Act 2025 decides what that company means for its owner: Nigeria now reaches income earned abroad, including profit left in a foreign company.
This guide puts the two systems together: the documents, the Nigerian rules, the arithmetic of bringing the dividend home, and funding the company.
What Bulgaria asks of a Nigerian founder
- One owner and one manager, who can both be Nigerian.
- EUR 1 of capital, deposited in a Bulgarian bank before registration.
- A power of attorney for the Bulgarian lawyer, with a certified Bulgarian translation.
- A registered address in Bulgaria.
Documents take the consular route. Bulgaria is a party to the Apostille Convention, Nigeria is not. A Nigerian power of attorney or company document needs authentication in Nigeria and legalisation by the Bulgarian embassy in Abuja, then a certified translation. Start this chain first. The registry steps are in how to register a company in Bulgaria.
How Nigeria taxes the owner from 2026
| Rule | Section | What it says |
|---|---|---|
| Resident individual | 12 | Taxed on income wherever it arises |
| Nigerian company | 6(1) | Includes a company effectively managed or controlled in Nigeria |
| Controlled foreign company | 6(2) | Undistributed profits that could have been distributed are treated as distributed |
| Unilateral relief | 119 | Credit for foreign tax, capped at the Nigerian tax on that income |
| Foreign dividends brought home | 162(1)(s) | Exempt when brought into Nigeria through approved channels |
| Individual rates | Fourth Schedule | Up to 25% above NGN 50 million |
- Residence is broad: domicile, a permanent home, habitual abode, economic and family ties, or 183 days in twelve months.
- Report it yourself: a yearly self-assessed return of income from every source.
- CFC details are pending from the Nigeria Revenue Service.
3 questions
Which jurisdiction fits you?Answer three questions and get the three jurisdictions that match your situation.
Management: keep the company Bulgarian
An EOOD whose every decision is taken in Lagos can be a Nigerian company under section 6(1), taxed on its whole profit in Nigeria. And under section 6(2), profit kept in the EOOD may be treated as distributed anyway.
- Give the Bulgarian manager real authority, recorded in minutes.
- Sign contracts and hold meetings in Bulgaria.
- Keep the books, the accountant and the bank in Bulgaria.
The dividend: bring it home
| On 100 of Bulgarian profit | Dividend brought home | Dividend left abroad |
|---|---|---|
| Bulgarian corporate tax, 10% | 10.00 | 10.00 |
| Dividend paid | 90.00 | 90.00 |
| Bulgarian withholding, 5% | 4.50 | 4.50 |
| Nigerian tax on the dividend, 25% | 0 | 22.50 |
| Credit under section 119 | 0 | 4.50 |
| Total tax on 100 of profit | 14.50 | 32.50 |
Three cautions: the right-hand column assumes the top band; we credit only the withholding, not the corporate tax; and "approved channels" is not defined in the section, so confirm what your bank and the revenue service accept.
No tax treaty with Bulgaria
Nigeria is not on Bulgaria's treaty list. Bulgarian rates apply in full: 5% on dividends, 10% on interest, royalties and technical services. Relief in Nigeria comes only from section 119. See Bulgarian corporate tax.
Funding the company from Nigeria
Nigeria does not forbid investing abroad; the constraint is access to foreign currency under the Central Bank's Foreign Exchange Manual, 4th edition, dated 1 June 2026.
| Point | Position | Source level |
|---|---|---|
| Outward investment | Not restricted for domestic firms | Government summary |
| Self-funded domiciliary account | Form A no longer required for outward remittances | Law firm summary |
| Direct transfers | Up to USD 10,000 a day without full trade documents | Law firm summary |
Check each line with your bank. A Bulgarian bank will ask for the source of funds, so keep the paper trail: the route that funds the company is also the approved channel the dividend comes back through. See the bank account guide.
- 1Where will the company be managed?In Bulgaria, or it may be Nigerian under section 6(1)
- 2How will the capital leave Nigeria?Through your bank, documented
- 3How will the dividend come back?The same approved channel, to use section 162
- 4Then register in BulgariaWith documents legalised in Abuja
Visa and moving to Bulgaria
Bulgaria has been a full Schengen member since 1 January 2025; Nigerian citizens need a Schengen visa for the bank visit and a D visa to live there as manager, as described in non-resident founders. A founder who truly leaves Nigeria stops being taxed there on new foreign income; Nigerian residence tests are broad, so confirm you have left before relying on it.
The bottom line
A Bulgarian EOOD works for a Nigerian founder if it is managed in Bulgaria and the dividend comes home through approved channels: about 14.5 of tax on 100 of profit. Leave the dividend abroad and Nigeria's tax more than doubles it. Plan the legalised documents and the money path before you register.
corpsec registers the Bulgarian company and provides its registered address. See the Bulgaria formation service, or read what the company costs.
Frequently asked questions
Can a Nigerian open a company in Bulgaria?
Yes. An EOOD can have a single Nigerian owner and manager, with EUR 1 of capital. Nigerian documents need legalisation by the Bulgarian embassy in Abuja, since Nigeria is not an Apostille party.
Does Nigeria tax profit kept in a Bulgarian company?
It can. Under section 6(2) of the Nigeria Tax Act 2025, undistributed profit of a controlled foreign company that could have been distributed is treated as distributed.
Are foreign dividends taxed in Nigeria?
Foreign dividends brought into Nigeria through approved channels are exempt under section 162(1)(s). Otherwise they are taxed at your rate, with a credit for foreign tax.
Does Nigeria have a tax treaty with Bulgaria?
No. Bulgaria's 5% on dividends and 10% on interest, royalties and services apply in full.
Do Nigerians 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
- Nigeria Tax Act 2025 (Act No. 7, Official Gazette of 26 June 2025), copy hosted by the Tax Appeal Tribunal: worldwide income of residents (sections 6 and 12), controlled foreign companies (section 6(2)), unilateral credit (section 119), exemption of foreign dividends brought home (section 162)
- Nigeria Tax Administration Act 2025 (Act No. 5), copy hosted by the Tax Appeal Tribunal: annual self-assessed return of income from every source
- PwC Worldwide Tax Summaries, Bulgaria, Foreign tax relief and tax treaties (reviewed 2 August 2026): Nigeria is not among Bulgaria's treaty partners
- HCCH status table of the Apostille Convention: Bulgaria is a party, Nigeria is not listed
- Deloitte, Bulgaria Highlights 2026: 10% corporate income tax and 5% withholding on dividends paid to non-residents
Official, read on 5 October 2026 for this series: the Nigeria Tax Act 2025 and the Nigeria Tax Administration Act 2025 as gazetted on 26 June 2025, in the copies hosted by the Tax Appeal Tribunal, whose two file names are swapped; the HCCH status table. Read on 26 October 2026: PwC's Bulgarian treaty list and Deloitte's Bulgaria Highlights 2026. Secondary: the Central Bank of Nigeria Foreign Exchange Manual, 4th edition, read through a law firm summary. Our calculations assume the top 25% band for a Nigerian individual and credit only the Bulgarian withholding, not the Bulgarian corporate tax; confirm both with your adviser. The Nigeria Revenue Service's detailed rules on controlled foreign companies were not found. The legalisation chain should be confirmed with the Bulgarian embassy in Abuja. This is not legal or tax advice.