Most people arrive here having already been told to “get a certificate.” Usually a bank, a foreign payer or a tax office abroad has asked for proof that Bulgaria taxes you, so that treaty relief can be applied to a dividend, a royalty, an interest payment or employment income.
The document itself is straightforward. It is requested on form Okd-273 under Chapter Twelve of the Tax and Social Security Procedure Code, it carries no state fee, and under Art. 90(1) DOPK the National Revenue Agency has seven days to issue it from receipt of the request — fourteen where the request is filed through a different territorial directorate.
We tell people this openly, because it decides whether you need us at all. If your position is clean and obvious, file it yourself. Our work begins where the position is arguable.
What the NRA is actually deciding
The certificate is not a reward for having a company here, an address here or a residence card. It confirms that you are a Bulgarian tax resident under Art. 4 of the Personal Income Tax Act, which sets out four alternative grounds — a permanent address, presence of more than 183 days in any twelve-month period, a posting abroad by the Bulgarian state or a Bulgarian undertaking, or a centre of vital interests in Bulgaria. Any one of them is enough, and Art. 4(1) says so expressly regardless of citizenship. Two details decide more cases than people expect: the day of entry and the day of exit each count as a day of presence, and a stay here purely for study or medical treatment does not count at all.
The one that trips people up is the first. Under Art. 4(5), a person with a permanent address in Bulgaria is expressly not a Bulgarian tax resident if the centre of vital interests lies outside the country. And Art. 4(4) says what that centre is measured by: the family, the property, the place from which the person carries on their work or business, and the place from which they manage that property. That is where most weak files fail, and it is also the ground a foreign authority is most likely to test.
The certificate is issued for one country and one tax year. Two treaty countries across two years is four separate applications on Okd-273, not one document used four times. This surprises almost everyone, and it is the reason a certificate is rarely a one-off errand.
How we run it
Establish the ground before anything is filed
We work out which of the four grounds your facts actually support, and how defensible it is. If the answer is that you are not yet a Bulgarian tax resident, you hear that first — before a refusal puts it on the record.
Build the evidence file
Day counts that survive scrutiny, civil-registry documents, proof of where your economic and personal life sits. The application is short; the file is what carries it.
Prepare and file Okd-273
Filed with the competent territorial directorate so the seven-day period applies, naming the correct country and tax year. Individuals and sole traders complete Part II.
Handle the NRA’s questions
The agency can ask for further evidence, which is the usual reason a “seven-day” certificate takes longer. We answer those requests directly.
Check how it will read abroad
Bulgaria has more than seventy treaties in force and they are not drafted identically. We read the operative text of the one you need, and coordinate translation, notarisation or apostille where the receiving authority requires it.
Appeal a refusal, if it comes to that
Failure to decide in time counts as a tacit refusal (Art. 91(2)). A refusal is appealed to the territorial director within fourteen days of notification (Art. 92(1)), and then to the administrative court at your permanent address or seat within seven days (Art. 95(1)). The court route only opens once the administrative one is exhausted, and its decision is final.
What is and isn’t in scope
We would rather be exact about this at the start than discover a gap halfway through.
Included
- Assessment of your residency ground and how well it is supported
- Building the evidence file and listing what you need to obtain
- Preparing and filing Okd-273, per country and per tax year
- Correspondence with the NRA, including evidence requests
- Reading the relevant treaty and advising how the certificate should be presented
- Appealing a refusal, administratively and before the court
Not included
- Any influence over the NRA’s decision — it rules on the file, and no one can promise an outcome
- Third-party costs: sworn translation, notary, apostille, courier
- Filing or arguing your case before a foreign tax authority — we work with your adviser there
- De-registration from your home country’s tax system, which follows its own rules
- Manufacturing a residency position that the underlying facts do not support
See your own position first
Our certificate check walks through the four grounds, shows how many separate filings your countries and years actually require, and flags where a treaty is worth reading. Two minutes, no account, nothing stored unless you ask us to.
Open the certificate checkWhen this is worth paying for — and when it isn’t
Talk to us if
- A foreign authority has already questioned where you are resident
- You could be treated as resident in two countries at once
- Your ground rests mainly on centre of vital interests
- You need certificates across several countries or several years
- Significant treaty relief turns on the certificate being accepted
- A previous application was refused
You probably don’t need us if
- You have lived in Bulgaria continuously and it is not in dispute
- Your day count is unambiguous and documented
- You need one certificate, for one country, for one year
- No one has challenged your position
If you are in the second column, the form is public and the procedure is free. We will tell you so.
Why this sits with a law firm
A certificate is a small document attached to a much larger question: which country has the right to tax you. That question is answered by domestic law, by a treaty, and sometimes by two authorities disagreeing — and it can be reopened years later, when the file is cold and the person who assembled it has moved on.
Formation agents can fill in a form. What they cannot do is take a position on residence, defend it in an appeal, or represent you before the NRA if the year in question is later examined. We are a Bulgarian law firm with a tax practice; residence, treaty analysis and revenue-authority representation are the same practice, not three different vendors.
Questions people ask before getting in touch
Does the NRA charge for the certificate?
No. It is issued free of charge. What costs money is the evidence behind it, any translation, notarisation or apostille the receiving country wants, and professional time. We say this plainly because a service built on hiding it would not last.
How long does it take?
Seven days from receipt under Art. 90(1) DOPK; fourteen where it is filed through a different territorial directorate. If the NRA asks for more evidence, expect longer in practice. Filing correctly the first time is what keeps it short.
Do I need a separate certificate for each country?
Yes — one country, one tax year, one application. Several treaty countries or several back years means several filings, which is worth planning in one go rather than discovering one at a time.
Can I do it myself?
Often, yes. The form is public and there is no fee. Pay for advice when the ground is arguable, when someone abroad has challenged you, or when a refusal has to be appealed.
What if the NRA refuses?
Fourteen days to the territorial director from notification (Art. 92(1) DOPK), then seven days to the administrative court at your permanent address or seat (Art. 95(1)). Not deciding in time is itself a tacit refusal and is appealable on the same terms. The court can order the document issued, and its decision is final — but a refusal is far easier to avoid than to undo.
Does my residence card make me a tax resident?
No. Residence status and tax residence are decided under different rules. A residence card can support a file, but it does not answer the Art. 4 question on its own. We wrote about that separately.
Read the detail first, if you prefer
How to get the certificate from the NRA
The full procedure, documents, timings and the usual reasons an application is refused.
The decisive testCentre of vital interests, in twelve factors
What the NRA and foreign authorities actually weigh when the 183-day count is not conclusive.
Counting properlyThe 183-day rule
Which days count, how the twelve-month window works, and what evidence survives scrutiny.
Tell us where you stand
Describe your situation in a few lines — where you live, where the income comes from, and who has asked you for the certificate. We will tell you whether you need us, and what the file would have to show.