Bulgaria for Mobile App Developers App Store, Google Play, AdMob & the 10% Tax

If you ship mobile apps to the App Store or Google Play and you are deciding where to base the operation, Bulgaria is one of three or four credible answers in the EU. The 10% flat corporate income tax (combined 15% with the 5% dividend), the 7.5% effective freelancer regime for indie devs under EUR 30,000-40,000 annual revenue, the Sofia developer talent pool, and the fact that Apple and Google handle EU consumer VAT for you under the deemed-supplier rule make the math work — provided you set up the compliance file correctly. The trap most app devs walk into in their first year is not the tax rate. It is the missed Article 97a VAT registration on the platform commission and on AdMob income, the incorrect W-8BEN-E on the Apple Developer Account, and the misconception that "App Store handles everything, I have nothing to file." None of those are tax-rate problems. They are compliance-setup problems we see every quarter on retainer onboarding.

Why Bulgaria for an App Developer

Mobile app developers cluster around two or three jurisdictions in Europe: Ireland (corporate tax 12.5%, post-2024 effective rate at 15% under Pillar Two for large groups), Cyprus (corporate tax 12.5% rising to 15% from 2026 under Pillar Two compliance), Estonia (deferred taxation — only on distribution), and Bulgaria (10% flat CIT, 5% dividend). The right answer depends on team size, target ARR and whether you intend to sell the studio.

Bulgaria's case in 2026:

• 10% flat CIT — the lowest standard corporate rate in the EU.
• 5% dividend withholding on distributions — combined effective 15% on profit drawn out. Bulgaria corporate tax 2026 guide covers the full mechanics.
• 7.5% freelancer regime for solo indie devs under Article 29(1)(3) of the Personal Income Tax Act — 25% automatic deemed expense deduction, 10% PIT on the remaining 75%. See our Bulgaria freelancer tax guide.
• Sofia developer talent pool — competitive senior engineering rates, English-fluent, EU work authorisation by default.
• EU member state status with eurozone entry effective 1 January 2026 — no FX hedge required against EUR-denominated platform payouts.
• Tax treaty network covering 70+ countries — including the United States (5% royalty withholding on App Store payouts), the United Kingdom, Germany, France, the Netherlands.
• Investment Promotion Act incentives for studios that hit certain hiring and investment thresholds — material once you scale past 10-15 employees.

Bulgaria's case is strongest for two segments: (a) indie developers under EUR 40,000 annual revenue, who can run a freelancer registration and pay roughly 7.5% effective tax; (b) studios with ARR under USD 1 million that benefit from Apple's reduced 15% commission and want a clean EOOD running 15% combined tax. Above USD 1 million ARR the rate stack interacts with Pillar Two and the App Store reduced-rate cliff — book a call so we can model the case to your specific group structure.

The Tax & VAT Stack for a Bulgarian App Developer

Four EU-level layers and three Bulgarian-level layers govern the tax and VAT picture for a Bulgarian-domiciled app developer in 2026. Reading the layering matters because most public-internet advice from platforms or accountants describes a single layer in isolation.

The reading order: Article 9a tells you what you do not have to do (charge VAT to end consumers); Article 97a tells you what you do have to do (register for cross-border B2B with Apple, Google, AdMob); the corporate or personal income layer tells you what rate applies to net revenue once it lands in your bank account.

How Apple and Google Handle EU Consumer VAT for You

This is the single most misunderstood point in app-developer tax. Three quarters of the new clients we onboard arrive worried about "App Store VAT" and how to charge it. The answer in 2026 is the same as it has been since 2015: you do not charge App Store VAT to end consumers, because Apple does it for you under EU law.

The legal basis — Article 9a of the EU VAT Implementing Regulation

Article 9a of Council Implementing Regulation (EU) 282/2011, implementing Article 28 of the EU VAT Directive, creates a deemed-supplier presumption for electronic services supplied through an electronic interface — including app marketplaces. Where the platform authorises the charge to the customer, processes the payment or sets the general terms of supply, the platform is treated as the supplier to the end consumer for VAT purposes. The validity of Article 9a was confirmed by the Court of Justice in Case C-695/20 Fenix International (28 February 2023).

What this means operationally

When a French consumer buys your app for EUR 4.99 on the App Store:

• Apple charges the consumer EUR 4.99 inclusive of French VAT at 20%.
• Apple separates the VAT (EUR 0.83) and remits it to the French tax authority.
• From the remaining EUR 4.16, Apple takes its commission (30% under standard terms, 15% under the small-business programme, or the layered fee stack under the EU DMA framework).
• You receive the net payout — typically USD-denominated in your developer account — without ever entering the transaction into your Bulgarian VAT return as a sale to the end consumer.

The Article 97a residual obligation

Article 9a takes the B2C consumer-facing VAT obligation off the developer's plate. It does not remove the B2B obligation on the developer-to-platform relationship. Apple is a US entity (Apple Inc.) for the developer agreement, with various EU subsidiaries acting as VAT-registered entities for European distribution. Google operates through Google Asia Pacific Pte Ltd in Singapore for some flows and Google Ireland for others. Either way, the developer-to-platform transaction (Apple's commission, Google's service fee) is a B2B cross-border digital service, and the developer needs Article 97a partial VAT registration in Bulgaria from the first month the platform commission is debited.

Shipping for 12+ months without Art. 97a? Send a 1-line message and we will email back the Art. 97a remediation cost sheet — no call required, no commitment.

Apple's 2026 EU DMA Cost Stack — What Actually Changed

The Digital Markets Act (Regulation (EU) 2022/1925) forced Apple to restructure its EU developer terms. As of 1 January 2026 Apple consolidated its EU framework into a single layered fee model that replaced the EUR 0.50 per-install Core Technology Fee with a 5% Core Technology Commission on digital goods and services revenue. Three components apply, in different combinations, depending on the distribution path and payment system you use.

For a developer using external payments under the new EU optional terms, the combined fee stack can reach about 20% (2% + 13% + 5%) versus the 30% standard App Store commission. Tier 1 Store Services + Core Technology Commission lands at around 10%; the catch is loss of App Store editorial and recommendation surfaces. Small developers under approximately EUR 10 million global revenue receive a concessional Core Technology Commission ramp under Apple's Small Developer Programme — verify the exact 2026 conditions against Apple's live developer.apple.com policy at the time you commit. This is a commission economics decision, not a tax decision — but the net payout that lands in your Bulgarian bank account depends on it.

Google Play's 2026 Fee Changes

Google announced its 2026 Play Store restructure on 4 March 2026 following the global settlement with Epic Games. The changes roll out from 30 June 2026 in the US, UK and EEA. Three points matter for a Bulgarian app developer.

1. Subscription fee dropped to 10% headline (15% effective with Play Billing)

Subscription service fees drop to 10% starting 30 June 2026 — with the US as the lead market and the UK and EEA staged through the second half of 2026. Verify the exact EEA rollout date against the live Play Console policy when you commit. A separate 5% billing fee applies if developers use Google Play Billing — so the effective rate for subscriptions using Play Billing is 15% total. For an indie dev with a freemium-plus-subscription model, this is a material reduction; for a fully free app monetised via ads, it changes nothing.

2. New install vs existing install distinction

The applicable service fee will be determined by whether the transacting user's install is "new" or "existing" — 15% for new installs under Google's Apps Experience programmes, 20% for existing installs. Existing user-base economics get more expensive; user-acquisition gets cheaper. Studios with mature long-tail user bases need to remodel LTV — we run the recalculation for retained studio clients during the Q3 2026 reconciliation.

3. EEA external-offers programme — fixed per-install fee

For developers who use the new system to link to direct app downloads outside the Play Store, Google introduces a fixed fee per install instead of a revenue share — varying by country and app type. In Group 1 countries (Germany, Ireland and others) the Tier 1 fee is EUR 0.90 per app install, EUR 0.95 per game install. Bulgaria's tier classification has not been published as of June 2026; we monitor for retained clients.

The Google Play VAT mechanics are identical to Apple's: Play acts as deemed supplier to the EU consumer under Article 9a, charges destination-country VAT, remits to the relevant Member State. The developer's Bulgarian VAT obligation is the same B2B Article 97a registration on the platform commission, no change.

AdMob, AppLovin, Unity Ads — The VAT You Actually Have to Handle

If your monetisation model is ads rather than paid downloads, the VAT picture changes shape. Ad-network revenue does not run through the deemed-supplier rule because there is no consumer-to-platform transaction — the consumer sees an ad inside your app, the ad network pays you (the developer) a share of the advertiser's spend. This is a B2B service between the ad network and the developer.

Place of supply and Article 97a

Under Article 21(2) of the EU VAT Directive (Article 21(2) ЗДДС in Bulgarian implementation), the place of supply of B2B services between taxable persons is the customer's Member State — the same mechanic we cover in detail in the Bulgaria SaaS VAT & OSS guide for cloud-services counterparts. Apply that to the developer-network pair:

• AdMob (Google Ireland Limited) → EU-to-EU B2B service → place of supply Bulgaria → reverse charge in Bulgaria → Article 97a registration required.
• AppLovin (AppLovin EU Limited, Ireland — parent AppLovin Corporation, Delaware/California; not to be confused with ironSource, which AppLovin acquired in 2024) → place of supply Bulgaria → Article 97a registration required.
• Unity Ads (Unity Technologies Denmark / Finland) → EU-to-EU B2B → place of supply Bulgaria → Article 97a registration required.
• US-domiciled ad-tech (older Vungle, Tapjoy, X Ads) → non-EU B2B service → place of supply Bulgaria → reverse charge still applies but no VIES filing for non-EU counterparties.

How the VAT entry actually flows

The Bulgarian developer issues a sales invoice to the ad network with zero Bulgarian VAT under reverse charge ("VAT to be accounted for by the recipient — Article 196 of Directive 2006/112/EC"), the ad network self-assesses VAT in its home Member State, and the Bulgarian developer files the monthly VAT return showing the supply on the sales side and the monthly VIES return showing the EU customer. No Bulgarian VAT is collected from the ad network and no input VAT is credited — Article 97a is a partial registration, not a full one. Total Bulgarian VAT owed on the AdMob revenue stream: zero. Total reporting obligation: monthly VAT return plus monthly VIES return.

Send us your last AdMob payout statement and we will return a one-page Article 97a + VIES exposure read within 48 hours. Async, no call required.

EOOD vs Freelancer — The Math For an App Developer

For a Bulgarian app developer the choice between an EOOD (limited liability company) and a freelancer registration is the single biggest setup decision. The math depends on revenue, team size and exit plans.

The 7.5% freelancer math, step by step

You earn EUR 30,000 gross in a calendar year from App Store payouts. Under Article 29(1)(3) of the Personal Income Tax Act, a freelancer in a "свободна професия" (free profession) — which in NRA practice typically includes software development activity under the freelancer regime subject to BULSTAT registration as a free professional — gets a 25% automatic deemed expense deduction with no receipts required. Taxable base: EUR 22,500. PIT at 10% flat: EUR 2,250. Effective tax rate: 7.5% of gross. Social security contributions are separate (chosen on a base between the minimum monthly insurable income and a statutory cap) and average around 27.8% combined for a self-insured third-category individual, but the chosen base controls actual amounts — most indie devs select the minimum base for cash-flow efficiency.

The 15% EOOD math, step by step

The same EUR 30,000 lands in a Bulgarian EOOD. CIT at 10% on net profit (after deducting actual expenses — desk, software subscriptions, freelancer payments, accountant): say EUR 24,000 profit after legitimate deductions → EUR 2,400 CIT. To draw the after-tax EUR 21,600 out as dividend: 5% dividend withholding = EUR 1,080. Total tax: EUR 3,480. Effective rate: 11.6% of gross — but the freelancer's tax was 7.5%. The EOOD is more expensive at this revenue band.

At EUR 80,000 gross, the picture inverts. Freelancer base after 25% deemed expense: EUR 60,000 × 10% = EUR 6,000 tax (7.5% effective, unchanged). EOOD with EUR 65,000 profit after real expenses: distribute everything and the EOOD costs EUR 9,425 (EUR 6,500 CIT + EUR 2,925 dividend on EUR 58,500 distributable); retain profit in the company and you pay only EUR 6,500 that year. That distribution-timing control is the EOOD's structural advantage over freelancer — alongside liability shielding and team scalability. The freelancer wins on simplicity. The inflection point in practice is between EUR 30,000 and EUR 50,000 ARR depending on real expense profile.

Send your last 3 months of platform payouts and we will email back an EOOD-vs-freelancer model to the euro within 48 hours. Async, no call required.

US Withholding on App Store and Google Play Payouts

Apple Developer Account and Google Play Console are US-based account setups. The default IRS treatment for non-US tax residents is 30% backup withholding on US-source income, including app sale royalties. The Bulgaria-US Income Tax Treaty (signed 23 February 2007, in force 15 December 2008) overrides the default for Bulgarian tax residents:

• Article 12 of the treaty — royalties from the use of, or right to use, copyright of literary, artistic or scientific work (including computer software) sourced in the US and paid to a Bulgarian resident: 5% withholding cap.
• Article 7 (business profits) vs Article 12 (royalties) characterisation — US tax practice has, in several rulings, characterised App Store and Google Play payouts to non-US developers as business profits rather than software royalties (no US permanent establishment → 0% US withholding). Whether the App Store payout to a Bulgarian EOOD is royalty (5% cap under Art. 12) or business profit (0% under Art. 7) depends on the developer agreement and US tax practice at the time. Many BG EOODs operate with no US withholding at all because of this characterisation — verify with a US tax practitioner on first setup.
• Article 23 of the treaty — credit method for relief of double taxation. The 5% US tax (if any) is creditable against the Bulgarian tax on the same income, capped at the Bulgarian tax attributable to that income.
• W-8BEN-E (for an EOOD) or W-8BEN (for an individual freelancer) must be filed in the Apple Developer Account and Google Play Console at account creation. The form claims treaty benefits and reduces backup withholding from the 30% default.

For a typical Bulgarian app developer, the practical outcome is that any US withholding is creditable against Bulgarian tax — net additional tax cost: typically zero for Bulgarian-resident developers paying tax on the same income. The trap is when the W-8 is not filed, or is filed under the wrong entity, or expires (W-8 forms have a 3-year validity from end of the year signed). Then 30% backup withholding hits, and recovery requires filing IRS Form 1042-S claim with a Bulgarian tax residency certificate — a 6-12 month timeline.

IP, Copyright & Asset Holding

For a solo indie developer, the right answer is almost always: hold the IP in the operating entity (EOOD or in personal hands as freelancer) and do not over-engineer. For a studio with team contributors, the IP question becomes substantive.

Copyright vesting

Under the Bulgarian Copyright and Related Rights Act (Закон за авторското право и сродните му права), software copyright vests in the author by default. For employed developers within a Bulgarian EOOD, Article 14 of the Act provides that the economic rights in software created in the course of employment vest in the employer — provided this is properly documented in the employment contract. We draft this clause as standard in EOOD employment contracts for app-developer clients; absence of the clause is a material defect on M&A diligence.

Contractor and freelancer contributors

For non-employee contributors — freelance designers, music composers, beta-test communities — the default IP vesting is with the contractor. A written IP assignment is mandatory for the EOOD to own the work product unambiguously. We use a standard IP assignment clause in our app-developer contractor template; without it, the studio finds out at exit that 12% of its codebase or 30% of its visual assets are owned by departed contractors.

Separate IP holding company — when it makes sense

Splitting IP into a separate Bulgarian holding company that licenses to an operating EOOD creates two layers of corporate tax — 10% at the operator (with the royalty fully deductible at that level) and 10% at the holder on the royalty income received — plus a transfer-pricing documentation obligation under the Corporate Income Tax Act and operational complexity. The structure becomes net-efficient at scale — typically EUR 500,000+ annual licensing revenue when it pays for itself through:

• Litigation isolation — IP outside the operating company is protected from operating-company liability.
• M&A optionality — selling either the IP or the operating company independently.
• Investor structuring — investors take equity in the holdco; IP stays clean.

For a sub-EUR 500,000 indie operation the structure costs more than it saves. We model the inflection point case-by-case.

Studio at Scale — Pillar Two, SSC and the EUR 750m Group Threshold

Three structural points become decision-driving once an app studio crosses the indie/studio boundary.

Pillar Two top-up for very large groups

The OECD/EU Pillar Two framework — implemented in the EU through Council Directive (EU) 2022/2523 and in Bulgaria through the 2024 amendments to the Corporate Income Tax Act — imposes a 15% minimum effective tax on multinational groups with consolidated revenue above EUR 750 million in two of the prior four years. A Bulgarian EOOD that is part of such a group pays a top-up via the Income Inclusion Rule, Undertaxed Profits Rule or Qualified Domestic Minimum Top-Up Tax to bring effective tax to 15%. For most app studios this is irrelevant; it becomes relevant only on acquisition by, or roll-up into, a large game/app holding group. Below the EUR 750 million threshold the standard 10% Bulgarian CIT applies unchanged.

SSC ceiling and effective payroll cost

Social security contributions in Bulgaria are split between employer and employee and applied to a monthly insurable income capped at the statutory maximum — EUR 2,045 per month in 2026 (the legacy BGN 4,000 statutory cap at the 1.95583 conversion). Combined SSC + health-insurance rate on the cap is approximately 33.4% for an employee and 32.7% for a self-insured third-category individual. The cap matters: for a senior engineer earning EUR 4,000+ monthly, SSC stops accruing above EUR 2,045 — effective payroll loading is materially below the headline rate, which is one reason Bulgarian net-take-home for senior engineers compares favourably to Western European jurisdictions even at lower gross.

BASSCOM membership, Innovation Strategy 2030 and the R&D super-deduction

Studios with stable employment can benefit from BASSCOM (Bulgarian Association of Software Companies) membership for industry advocacy and access to the Investment Promotion Act incentives for designated investment classes. The Bulgarian Innovation Strategy 2030 (Иновационна стратегия за интелигентна специализация) includes a software-and-ICT priority axis with EU-cofunded operational programme support. Specific R&D super-deductions are narrower than in Ireland or Poland; for most app studios the practical benefit comes from grant programmes rather than tax credits. We screen for relevant programmes at retainer onboarding for studios above 5 FTE.

Five Compliance Mistakes We Catch on Audit

From the new app-developer clients we onboard each quarter, five mistakes repeat with high frequency. None are fatal; all become more expensive the longer they sit.

1. Missed Article 97a registration

The dominant pattern. Developer ships on App Store or Google Play, never registers under Article 97a, files no monthly VAT returns and no VIES returns. After 12-24 months an NRA cross-check (Bulgaria receives VIES data from Ireland and Singapore on platform commissions) surfaces the discrepancy. Remediation: late registration, backdated returns, zero Bulgarian VAT owed but administrative fines under Article 178 ЗДДС — modest per individual return but cumulative across 12-24 months of missed filings, and increasing where aggravating factors apply.

2. Wrong W-8BEN-E on Apple Developer Account

Either the W-8 was not filed at all (default 30% US backup withholding applies and is not creditable beyond the 5% treaty rate), or the W-8 was filed under a previous entity name (sole trader, freelancer registration) and not updated when the EOOD took over. Remediation: refile the W-8 under the correct entity, file IRS Form 1042-S claim for over-withheld amounts (the timeline is slow — 6-12 months).

3. AdMob revenue mis-classified as VAT-exempt

Developers see "no VAT" on the AdMob payout statement and conclude that AdMob revenue is VAT-exempt or out-of-scope. It is neither — it is a reverse-charge B2B service, and the obligation is to report it on the Bulgarian VAT return as a supply with reverse charge. Remediation: backdated monthly returns; no Bulgarian VAT owed but reporting obligation triggered.

4. Personal-tax filing not matched to freelancer registration

Solo indie devs sometimes register as freelancers but file Bulgarian PIT (Form 50) without the 25% deemed expense deduction box correctly applied — paying 10% PIT on gross rather than 10% on 75% of gross. The error is recoverable through correction returns under the 5-year statute of limitations but routinely costs the freelancer EUR 1,500-3,000 in over-paid tax per year of error.

5. Late-or-no annual financial statements

For an EOOD, annual financial statements must be filed with the Commercial Register by 30 September of the following year, and the corporate tax return (Form 1010) with the NRA by 30 June. Missed deadlines trigger ЗС fines (EUR 102-1,534 per missed AFS publication after the 2024 amendments) and statutory interest on late CIT. Bulgaria tax calendar 2026 covers the deadlines comprehensively.

Three Adjacent 2026 Topics App Devs Now Have to Track

None of these are direct tax topics, but each affects the compliance file we run for app-developer retainer clients.

App Privacy Manifest + EU Data Act (in force 12 September 2025)

Apple's Privacy Manifest (mandatory since May 2024) and the EU Data Act (Regulation (EU) 2023/2854) reshape SDK choice for indie devs. Every analytics or ad-tech SDK embedded in your app is a GDPR Article 28 processor relationship that needs a written processor agreement — AdMob, Firebase Analytics, AppLovin, Unity Ads, AppsFlyer all require properly executed Data Processing Addenda. The Bulgarian implementing layer sits in the Personal Data Protection Act (ЗЗЛД); breach exposure is the standard GDPR sanction band. We screen SDK contracts at retainer onboarding.

Unity Runtime Fee reversal + Unreal 5% royalty as Bulgarian CIT deduction

Unity's Runtime Fee was reversed in September 2024 after community backlash. Unity Pro / Unity Enterprise per-seat costs and the Unreal Engine 5% royalty (after the USD 1 million per-product gross-revenue threshold) are deductible operating expenses for a Bulgarian EOOD under the Corporate Income Tax Act — full deduction in the year incurred, no capitalisation required at typical license sizes. For freelancer-registered indies the seat costs are personal expenses and not deductible against the 25% deemed-expense regime under Article 29(1)(3) — one more reason the EOOD wins above a certain license-cost level.

EU Digital Services Act for apps with user-generated content

If your app has a chat feature, comments, a leaderboard or any user-to-user messaging, the EU Digital Services Act (Regulation (EU) 2022/2065) classifies you as an intermediary service provider with notice-and-action, transparency reporting and (above 45 million EU users) VLOP obligations. Most indie and small studios sit far below the VLOP threshold but still have the baseline obligations — a notice-and-action contact, content-moderation transparency on request, and clear T&Cs in plain language. We provide template DSA-compliant T&Cs as part of the retainer for apps with any UGC surface.

What This Costs — and What It Should Not Cost

Three reference points for an app-developer client.

Setup

EOOD incorporation: EUR 600-1,200 professional fees including state fees. Freelancer registration: EUR 200-400. Adding Article 97a partial VAT registration: bundled (no separate charge in our retainer; EUR 150-300 at most providers if billed separately). W-8BEN-E filing assistance: EUR 100-200 if billed standalone, bundled in our retainer.

Innovires retainer pricing for app developers

Indie dev (solo, sub-EUR 100k ARR): EUR 180-260 per month covers monthly bookkeeping, monthly VAT + VIES, quarterly Apple/Google statement reconciliation, W-8 status check, annual closing, and quarterly legal advisory hours. Studio (3-10 contributors, EUR 100k-1m ARR): EUR 550-850 per month adds payroll, contractor payment compliance, IP assignment template management, and integrated employment-law advisory.

Standalone setup (incorporation + 97a registration + W-8 filing assistance + first bank account introduction) is included at retainer onboarding at no separate fee — we do not unbundle. If you need a one-shot setup without ongoing engagement, a Bulgarian accountant-only provider is the better fit.

Best fit: indie devs with USD/EUR 5k+ monthly platform payouts, or studios scaling beyond 3 contributors. Below that volume, you do not need a regulated law firm — a Bulgarian accountant-only setup is enough.

Common Myths to Ignore

"App Store handles all my Bulgarian taxes, I have nothing to file."

False. App Store handles the EU consumer-facing VAT via the deemed-supplier rule. You still owe Bulgarian corporate or personal income tax on the net payout, Article 97a partial VAT registration on the commission and ad income, monthly VAT + VIES filings, annual financial statements (EOOD) or annual PIT return (freelancer), and US treaty compliance via the W-8BEN(-E).

"AdMob payouts are tax-free because no VAT is charged."

False. No VAT is charged because the place of supply is the developer's Member State and the developer applies reverse charge — exactly the reason Article 97a registration is mandatory. The income is still Bulgarian taxable income.

"Apple's new EU DMA fees mean I should switch to external payments."

Mostly false for indie developers. The DMA fee path lowers Apple's commission take from ~30% to ~20%, but introduces accounting complexity (managing your own EU consumer VAT on the externally paid portion — outside Article 9a deemed-supplier) and reduces App Store discoverability. The math works for studios with high user-acquisition independence (existing user base, owned channels, mature LTV). For an indie pre-launch app dependent on App Store editorial features, the standard 30% (or 15% small-business) commission is still net better.

"Bulgaria's 10% tax is just for large companies."

False. The 10% corporate income tax is a flat rate from EUR 1 of profit to unlimited. The 5% dividend withholding is unchanged at any distribution size. There is no progressive band, no minimum effective rate (except for Pillar Two top-up at large group level — turnover above EUR 750 million across the group), no special-purpose-vehicle requirement.

"I have to incorporate before I can claim Bulgarian tax residency."

False. Tax residency for an individual is established by physical presence (183 days), centre of vital interests, or election under certain conditions. Incorporation is a corporate matter, independent of personal residency. See our 183-day rule guide for personal residency mechanics.

Frequently Asked Questions

Sources & Legal References

Primary EU and Bulgarian instruments referenced in this article.

• Council Implementing Regulation (EU) 282/2011, Article 9a — deemed-supplier rule for electronic interfaces (App Store / Google Play).
• Council Directive 2006/112/EC — EU VAT Directive (Article 28 and Article 21(2) underlying Art. 9a and place of supply for B2B services).
• CJEU Case C-695/20 Fenix International (28 February 2023) — confirms validity of Art. 9a deemed-supplier presumption.
• Council Directive (EU) 2020/285 — small enterprise VAT scheme (EUR 100,000 EU-wide threshold from 1 January 2025).
• Regulation (EU) 2022/1925 — Digital Markets Act (DMA) — the regulatory driver behind Apple's 2026 EU fee restructure.
• Apple Developer — DMA and apps in the EU — official 2026 fee structure documentation.
• Google Play Console — service fees — 2026 fee schedule including subscription fee changes.
• Закон за корпоративното подоходно облагане (ЗКПО) — Bulgarian Corporate Income Tax Act; 10% flat CIT, 5% dividend withholding.
• Закон за данъците върху доходите на физическите лица (ЗДДФЛ) — Bulgarian Personal Income Tax Act; Article 29(1)(3) freelancer regime with 25% deemed expense deduction.
• Закон за данък върху добавената стойност (ЗДДС) — Bulgarian VAT Act; Article 96 (EUR 51,130 mandatory threshold), Article 97a (cross-border B2B partial registration), Article 21(2) (place of supply).
• Закон за авторското право и сродните му права (ЗАПСП) — Bulgarian Copyright and Related Rights Act, Article 14 (employer ownership of software created in employment).
• Bulgaria-US Income Tax Treaty 2007/2008 — Article 12 (5% royalty withholding cap on software) and Article 23 (credit method for double-tax relief).

Disclaimer: This article provides general information on the 2026 Bulgarian tax and EU VAT treatment of mobile-app-developer revenue as of June 2026. It does not constitute individual legal or tax advice. Apple's and Google's 2026 EU fee schedules are subject to amendment; the deemed-supplier rule under Article 9a of Council Implementing Regulation 282/2011 is the operative VAT framework for platform-mediated B2C transactions. For a specific case please consult counsel. Last reviewed: June 6, 2026.