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Bulgaria-US Double Tax Treaty: What American Expats Need to Know

Published: April 8, 2026 | Last updated: April 8, 2026
Yordan Cholakov Apr 8, 2026 10 min read

The Problem Every American Abroad Faces

The United States is one of only two countries in the world (the other is Eritrea) that taxes its citizens on worldwide income regardless of where they live. Move to Bulgaria, build a life there, pay Bulgarian taxes in full — and the IRS still expects you to file. Every year. On everything.

The good news: the Bulgaria-US double tax treaty, combined with specific IRS exclusions and credits, means most American expats in Bulgaria can legally reduce or eliminate double taxation. The bad news: the compliance burden is real, and the penalties for getting it wrong are severe.

This guide covers every tax obligation an American citizen or green card holder faces when living in Bulgaria — from treaty withholding rates to FBAR filings to the tax chain of owning a Bulgarian company.

2008
Treaty in force since
5–10%
Treaty dividend WHT
$132,900
2026 FEIE exclusion
$10,000
FBAR reporting threshold

The Treaty at a Glance

The Convention between the United States and Bulgaria for the Avoidance of Double Taxation was signed on February 23, 2007, with an amending protocol signed on February 26, 2008. The treaty entered into force on December 15, 2008, and has been in effect for all tax years since.

Here are the key withholding tax rates the treaty sets for cross-border payments between the two countries:

Income TypeTreaty RateWithout Treaty (BG domestic)Notes
Dividends (10%+ holding)5%5%Beneficial owner holds at least 10% of voting power
Dividends (portfolio)10%5% (individuals) / variesAll other cases
Interest5%10%Reduced from domestic 10% rate
Royalties5%10%Reduced from domestic 10% rate
Capital gains (shares)Residence state onlyVariesGenerally taxed only where seller resides
Employment incomeWhere work performedN/A183-day exemption for short assignments
Business profitsResidence state onlyN/AUnless permanent establishment in other country

Key point: For a US citizen who owns a Bulgarian EOOD and receives dividends, the relevant rate is the 5% dividend withholding — because as the sole owner, you hold 100% of the voting power (well above the 10% threshold). This is also the standard Bulgarian domestic rate for individual dividend recipients, so the treaty rate and domestic rate align in this scenario.

For a broader overview of all Bulgarian tax treaties, see our complete guide to Bulgaria's double tax treaties.

The US Worldwide Taxation Problem

Most countries tax based on residency — if you leave, you stop owing tax. The United States taxes based on citizenship. This fundamental difference creates a unique burden for American expats:

This means a US citizen living in Sofia, earning only Bulgarian-source income, paying Bulgarian taxes in full, must still file a US federal tax return every year. And report every foreign bank account. And report foreign financial assets above certain thresholds. The filing obligations alone make US citizenship the most tax-intensive nationality to hold abroad.

Penalties are steep: Failure to file FBAR carries penalties up to USD 16,536 per violation for non-willful violations. Willful violations can reach the greater of USD 165,353 or 50% of the account balance. FATCA Form 8938 non-filing penalties start at USD 10,000. These apply per account, per year.

Foreign Earned Income Exclusion (FEIE)

The FEIE (IRS Form 2555) allows US expats to exclude earned income from US taxation — up to a set limit that adjusts annually for inflation.

2026 FEIE Threshold

For tax year 2026, the maximum exclusion is USD 132,900 per person. If both spouses work abroad and each qualifies, they can exclude up to USD 265,800 combined.

Qualifying Tests

You must meet one of two tests:

What the FEIE Covers — and What It Does Not

This distinction matters enormously for EOOD owners: your salary from the management contract qualifies for the FEIE, but your dividend distributions do not. For dividends, you need the Foreign Tax Credit.

Practical tip: The FEIE amount is adjusted annually by the IRS. Always verify the current year threshold at irs.gov before filing. The 2025 threshold was USD 130,000; the 2026 figure of USD 132,900 represents one of the largest single-year increases in recent history.

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Foreign Tax Credit (FTC)

The Foreign Tax Credit (IRS Form 1116) lets you credit taxes paid to Bulgaria directly against your US tax liability. Dollar for dollar.

How It Works

If you earn USD 100,000 in Bulgaria and pay 10% Bulgarian income tax (USD 10,000), you report the full USD 100,000 on your US return — but then claim a USD 10,000 credit. If your US tax on that income would have been USD 12,000, you owe only USD 2,000 to the IRS. If your US tax would have been USD 8,000, you owe nothing and carry the excess USD 2,000 forward for up to 10 years.

FEIE vs FTC: Which Is Better?

You cannot use both on the same income. Here is when each makes sense:

ScenarioBetter ChoiceWhy
Salary under USD 132,900, minimal BG tax paidFEIEExcludes all earned income; simple
Salary over USD 132,900FTCCredits BG tax on the full amount, no cap
EOOD owner taking dividendsFTCFEIE does not cover dividends; FTC credits both CIT and WHT
Mix of salary + passive incomeFTC (or split)FTC covers all income types; FEIE only covers earned income
Very low income, high BG social contributionsFTCBulgarian social security is not creditable, but income tax is; FTC maximizes the offset

Important: Once you elect the FEIE, you are locked in for that year and all future years unless you formally revoke it. Revoking the FEIE means you cannot re-elect it for five tax years without IRS approval. Choose carefully in your first year abroad.

FBAR and FATCA Reporting

Even if you owe zero US tax after applying the FEIE or FTC, you still have information reporting obligations. These are the two main ones:

FBAR — FinCEN Form 114

If you have a personal Bulgarian bank account and an EOOD business account, and their combined balance exceeds USD 10,000 at any point during the year — even for a single day — you must file the FBAR. Given that the threshold is roughly EUR 9,200, virtually every American with a Bulgarian bank account and any meaningful savings will trigger this requirement.

FATCA — Form 8938

FBAR and Form 8938 are separate filings. You may need to file both. The FBAR goes to FinCEN; Form 8938 goes to the IRS with your tax return. Different thresholds, different forms, different agencies. Many expats file the FBAR but forget Form 8938, or vice versa.

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Owning a Bulgarian EOOD as a US Citizen

Many American expats in Bulgaria open an EOOD (single-member LLC) to run their business. Here is the complete tax chain from company profit to your pocket, accounting for both Bulgarian and US obligations:

The Tax Chain

StepWhat HappensRateExample (EUR 100,000 profit)
1. Bulgarian CITEOOD pays corporate income tax on net profit10%EUR 10,000 tax; EUR 90,000 remains
2. Bulgarian dividend WHT5% withheld when distributing to individual owner5%EUR 4,500 tax; EUR 85,500 received
3. US reportingReport dividends on Form 1040 as foreign incomeVariesFull EUR 90,000 dividend is reported
4. Foreign Tax CreditCredit BG taxes (CIT + WHT) against US liabilityCreditUp to EUR 14,500 credit available
5. Net resultEffective combined rate15%EUR 14,500 total tax (BG); minimal to zero US tax

The combined Bulgarian rate is 15% (10% CIT + 5% dividend WHT). Because US tax rates on qualified dividends are typically 15% or 20% (depending on income bracket), the Bulgarian taxes paid generate enough Foreign Tax Credits to eliminate or nearly eliminate any additional US tax on the same income.

Additional US Reporting for EOOD Owners

Practical tip: The EOOD structure remains highly tax-efficient for US citizens despite the reporting burden. The 15% combined Bulgarian rate competes favorably with US self-employment rates, and the FTC mechanism prevents true double taxation. The key is getting the compliance right from year one. See our guide on how to pay yourself from a Bulgarian EOOD for the salary-dividend optimization strategy.

Social Security: No Totalization Agreement

The United States has totalization agreements with about 30 countries — but Bulgaria is not one of them. As of 2026, no US-Bulgaria totalization agreement exists, and none is currently under negotiation.

What This Means in Practice

This is the hidden cost. Many American expats plan their Bulgarian tax obligations around income tax (10% flat rate, 15% combined CIT + dividend) and overlook social security entirely. Without a totalization agreement, self-employed US citizens may pay social contributions in both countries simultaneously. Factor this into your planning from the start.

Practical Steps for US Citizens Moving to Bulgaria

If you are an American citizen or green card holder planning to move to Bulgaria — or already living there — here is your compliance checklist:

1

File Your US Tax Return Every Year

Form 1040 is mandatory regardless of where you live or whether you owe US tax. Report all worldwide income. Expats get an automatic extension to June 15, with a further extension to October 15 available on request. Visit irs.gov for current filing requirements.

2

Elect FEIE or FTC in Your First Year

Decide whether the Foreign Earned Income Exclusion or the Foreign Tax Credit is better for your situation. Remember: the FEIE election is sticky — revoking it locks you out for five years. If you have EOOD dividend income, the FTC is almost always more beneficial.

3

File FBAR by April 15 (Extended to October 15)

If the aggregate value of your foreign accounts exceeds USD 10,000 at any point during the year, file FinCEN Form 114 electronically at fincen.gov. Include your personal Bulgarian bank account AND your EOOD business account if you have signature authority.

4

File Form 8938 If You Meet the Thresholds

Expats living abroad: report specified foreign financial assets if they exceed USD 200,000 at year-end or USD 300,000 at any point (single). Married filing jointly: USD 400,000 / USD 600,000. Attach to your Form 1040.

5

File Form 5471 If You Own a Bulgarian EOOD

As a US person owning more than 50% of a foreign corporation, you must file Form 5471 annually with your tax return. Penalty for non-filing is USD 10,000. This form requires detailed financial statements of your EOOD.

6

Establish Bulgarian Tax Residency Properly

Register your address, obtain a personal number (LNCH), and apply for a certificate of tax residence from the NRA once you qualify. For non-EU citizens, you will need a D visa and residence permit through the Migration Directorate.

7

Hire a Cross-Border Tax Advisor

US-Bulgaria tax compliance requires expertise in both jurisdictions. You need a Bulgarian accountant for local filings and a US-qualified CPA or enrolled agent experienced with expat returns (Forms 2555, 1116, 5471, 8938). We can coordinate both sides.

Cross-Border Tax Compliance, Sorted

We coordinate your Bulgarian company formation, tax residency, and local filings — and connect you with a US CPA for the American side.

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"Is it really worth moving to Bulgaria if I still have to file US taxes?" — Yes. Bulgaria's 10% flat income tax and 15% combined CIT + dividend rate are among the lowest in Europe. The Foreign Tax Credit mechanism means you typically owe zero additional US tax on Bulgarian-taxed income. The compliance burden (FBAR, Form 8938, Form 5471) is real, but it is paperwork — not additional tax. With the right advisors, the annual cost of US expat filing runs EUR 1,000–3,000, which is trivially small compared to the tax savings versus most Western European countries.

"Can I just not file and hope the IRS doesn't notice?" — FATCA makes this strategy obsolete. Bulgarian banks report your account information to the IRS through the US-Bulgaria intergovernmental agreement. The IRS knows you have foreign accounts. Non-filing triggers automatic penalties. The Streamlined Filing Compliance Procedures exist for expats who are behind — use them before the IRS contacts you.

"Should I renounce US citizenship to escape the tax obligations?" — This is a drastic step with permanent consequences. Renunciation triggers an exit tax on unrealized gains if your net worth exceeds USD 2 million or your average annual net income tax for the five preceding years exceeds a threshold (check irs.gov for the current figure). Most American expats in Bulgaria find that proper tax planning eliminates double taxation without renouncing anything.

Ready to Move to Bulgaria? Let's Plan Your Tax Position

Tell us about your situation — US citizen or green card holder, income sources, whether you plan to open an EOOD — and we'll map out your Bulgarian + US tax obligations. Free, no obligation.

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Frequently Asked Questions

Do US citizens living in Bulgaria still have to file US tax returns? +
Yes. The United States taxes its citizens and green card holders on worldwide income regardless of where they live. If you are a US citizen or permanent resident living in Bulgaria, you must file a US federal tax return (Form 1040) every year, reporting your worldwide income — including Bulgarian salary, EOOD dividends, and any other income. You must also file FBAR if your foreign accounts exceed USD 10,000 in aggregate, and FATCA Form 8938 if your foreign financial assets exceed the applicable thresholds.
What are the withholding tax rates under the Bulgaria-US tax treaty? +
The Bulgaria-US double tax treaty provides reduced withholding rates: dividends are taxed at 5% if the beneficial owner holds at least 10% of the voting power, or 10% in all other cases. Interest is capped at 5%, and royalties are also capped at 5%. The treaty was signed on February 23, 2007, and entered into force on December 15, 2008.
Can I use both the FEIE and the Foreign Tax Credit? +
You can use one or the other for the same income, but not both on the same dollars. You may claim the FEIE on earned income (salary, self-employment) up to USD 132,900 for 2026, and then use the FTC on income not covered by the exclusion — such as dividends, interest, or earned income above the FEIE threshold. Many expats find the FTC more beneficial overall, but the optimal choice depends on your specific income level and sources.
Is there a US-Bulgaria social security totalization agreement? +
No. As of 2026, no totalization agreement exists between the United States and Bulgaria. This means US citizens working in Bulgaria may be subject to social security contributions in both countries simultaneously. Self-employed individuals and EOOD owner-managers face the highest risk of double contributions. Bulgarian social insurance contributions do not count toward US Social Security benefits, and vice versa.
How is my Bulgarian EOOD taxed if I'm a US citizen? +
Your Bulgarian EOOD pays 10% corporate income tax on profits. When you distribute dividends, Bulgaria withholds 5% on the net amount. The combined effective rate is 15%. On the US side, you report the dividends on your Form 1040 and claim a Foreign Tax Credit for the Bulgarian taxes paid (both CIT and WHT), which typically eliminates or significantly reduces additional US tax. You must also file Form 5471 annually as the owner of a foreign corporation.
What is the FBAR filing threshold for US expats in Bulgaria? +
You must file an FBAR (FinCEN Form 114) if the aggregate value of all your foreign financial accounts exceeds USD 10,000 at any point during the calendar year. This includes personal Bulgarian bank accounts, EOOD business accounts, and any other foreign accounts. The FBAR is filed electronically through FinCEN's BSA E-Filing System by April 15, with an automatic extension to October 15. Penalties for non-filing can reach USD 16,536 per non-willful violation.
What are the FATCA Form 8938 thresholds for expats abroad? +
For US expats living abroad and filing as single, Form 8938 is required if specified foreign financial assets exceed USD 200,000 on December 31 or USD 300,000 at any point during the year. For married couples filing jointly: USD 400,000 at year-end or USD 600,000 at any time. These thresholds are significantly higher than for US residents (USD 50,000 / USD 75,000 for single filers). Form 8938 covers bank accounts, investments, foreign pensions, and ownership interests in foreign entities like your EOOD.
Should I choose FEIE or FTC as a US expat in Bulgaria? +
For most US expats earning salary income in Bulgaria, the Foreign Tax Credit is often more beneficial because Bulgaria's 10% flat income tax generates credits you can carry forward for up to 10 years. The FEIE makes sense if your earned income is below or near USD 132,900 and you have minimal Bulgarian tax liability to credit. If you own an EOOD, the FTC is almost always better because it lets you credit the 10% Bulgarian CIT and 5% dividend withholding against your US tax. Consult a cross-border tax advisor for your specific situation.