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Bulgaria: Draft laws amending Corporate Income Tax Act, including Pillar Two clarifications

Amendments proposed to be retroactive to January 1, 2026.

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February 23, 2026

The Council of Ministers in January 2026 submitted to Parliament draft laws that would retroactively amend the Corporate Income Tax Act (CITA) effective January 1, 2026, to clarify certain provisions of the Pillar Two regime and introduce technical corrections related to Bulgaria's adoption of the euro from January 1, 2026.

The draft laws also include proposed provisions for:

  • 50% accelerated depreciation for electric vehicles (EVs)
  • 25% research and development (R&D) expense deduction
  • Tax exemption for rental income of religious organizations


For more information, contact a KPMG tax professional in Bulgaria:

Alexander Hadjidimov | ahadjidimov@kpmg.com

Rumyana Staneva | rstaneva@kpmg.com

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