YARD Law Co. · Reviewed 19 August 2026 · YARD Law Legal Team
Three things changed for the taxation of crypto-assets in Bulgaria, each with effect from 1 January 2026: the statute now calls them by their proper name, the effective rate is not 10% and the euro changed what counts as "currency trading" at all. Separately, from the same date the National Revenue Agency began receiving data about your transactions automatically.
This article deals with the taxation of individuals. For the MiCA licensing regime see our guide to the Bulgarian CASP licence.
The version of Art. 33(3) of the Personal Income Tax Act in force (as amended in ДВ issue 106 of 2023, issue 54 of 2025 and issue 30 of 2026, in force from 1 January 2026) provides that taxable income from the sale or exchange of shares, participating interests, compensatory instruments, investment vouchers and other financial assets, including crypto-assets, and from trading in currency other than the euro, is determined by taking the sum of the gains realised during the year, computed transaction by transaction, less the sum of the losses realised during the year, computed transaction by transaction, and reducing that figure by 10% for expenses.
Three consequences follow, each of which matters in practice.
For years the statute contained no definition and the Revenue Agency worked by analogy, treating "virtual currency" as a financial asset. The concept entered the Personal Income Tax Act by the amendment in ДВ issue 54 of 2025 - the same issue that promulgated the Markets in Crypto-Assets Act. Tax law and regulatory law now use the same concept, which was not the case before 2025.
The tax is 10%, but it is charged on 90% of the net annual result. On larger volumes that is a material difference, and it is routinely overlooked.
The text now refers to trading in "currency other than the euro". Until 31 December 2025, euro transactions were foreign-currency trading and fell within the provision. From 1 January 2026 the euro is the national currency and transactions in it fall outside that regime. This does not affect crypto-assets themselves, but it does affect crypto-to-fiat pairs and anyone reporting results across several currencies.
The mechanics are in Art. 33(4): the gain or loss realised on each transaction is determined by deducting the acquisition cost of the financial asset from the sale price.
The calculation is per transaction, not per portfolio. Gains from all transactions in the year are added, losses from all transactions in the year are deducted, 10% for expenses is applied to the difference, and 10% tax is applied to what remains.
Here also is the provision most publications get wrong. The second sentence of Art. 33(4) provides that where financial assets of one kind, issued by one person, have different acquisition costs and part of them is subsequently sold, and it cannot be proved which part is being sold, the acquisition cost of each is the weighted average price, determined on the basis of the acquisition cost of the assets of the same kind and issuer held at the date of sale.
In other words, the statute does not offer a choice between FIFO and weighted average. The weighted average is the statutory rule for cases where it cannot be proved which specific part is being sold. If you keep records that allow you to prove which units are sold, the proved cost applies. If you do not, the weighted average applies. The practical conclusion is that the quality of your records determines the basis, not a preference for an accounting method.
Two further rules from the same article. The acquisition cost is zero where there is no documented acquisition cost, including for property acquired by gift (Art. 33(6)(3)). And under Art. 11(2) income is treated as acquired on the date of transfer, not the date of payment.
This distinction matters more than the rate, because it changes the entire regime.
Art. 33 does not apply to income from the business activity of an individual who is a merchant within the meaning of the Commerce Act, including where that person is not registered as a sole trader. Under Art. 26(7) of the Personal Income Tax Act, such a person's taxable income is determined under the rules for a sole trader - that is, as taxable profit under the Corporate Income Tax Act - declared in Annex 2 and accompanied by social-security obligations as a self-insured person.
The test is objective. Under Art. 1(3) of the Commerce Act, a merchant also includes any person who has formed an enterprise which, by its subject matter and volume, requires its affairs to be conducted in a commercial manner. It is the transactions carried out, not the registration, that determine the status. The Revenue Agency has consistently maintained that mining crypto-assets is a business activity rather than a disposal of a financial asset: purchasing specialised computing systems with a view to profit from selling what is mined is an argument that the activity is carried on by way of trade.
Where trading is systematic in subject matter and volume, the same analysis can be applied to it. The line is not fixed numerically in the statute and is assessed on the facts. This is the question that deserves a written opinion before the return is filed, not after an audit.
From 1 January 2026 the answer to "how would the Revenue Agency find out" is specific.
DAC8 - Council Directive (EU) 2023/2226 - extends automatic exchange of information within the EU to crypto-assets. The transposition deadline was 31 December 2025 and the provisions apply from 1 January 2026. Calendar year 2026 is the first reporting year: crypto-asset service providers collect data on users' identity, holdings and transactions and report it to their competent authority, which exchanges it with the state of tax residence within nine months of the end of the reporting year.
CARF - the parallel OECD framework - also applies to Bulgaria. The multilateral competent authority agreement on automatic exchange under the Crypto-Asset Reporting Framework was ratified by a law promulgated in ДВ issue 23 of 27 February 2026; the agreement itself was promulgated in ДВ issue 50 of 2 June 2026 and has been in force for Bulgaria since 22 April 2026.
Neither DAC8 nor CARF introduces a new tax. They introduce visibility. The rate remains 10% with a 10% expense deduction, and Bulgaria remains among the most favourable jurisdictions in the EU for declared crypto income. What has ended is the practical invisibility of undeclared positions.
Income from the sale or exchange of crypto-assets is declared under Art. 50 of the Personal Income Tax Act in Annex 5 of the annual return. Mining income is declared in Annex 2.
No advance tax is due on income from the sale or exchange of crypto-assets. The liability arises with the annual return.
Under Art. 34, the annual tax base is determined by reducing the taxable income under Art. 33 by the contributions the person is obliged to make for their own account under Art. 40(5) of the Health Insurance Act, where the income is included in the annual equalisation of insurable income.
Filing deadlines for the annual return, and the conditions for the early electronic-filing discount, should be checked against Art. 53 of the Personal Income Tax Act as currently in force and against the return form for the relevant year.
An asymmetry that is missed almost everywhere.
Resident individuals benefit from the 10% expense deduction under Art. 33(3). Non-resident individuals without a fixed base in the country are taxed by a final withholding tax under Art. 37(1)(12) on income from the sale, exchange and other transfer for consideration of shares, participating interests, compensatory instruments, investment vouchers and other financial assets. Under Art. 37(4) that tax is charged on the positive difference between the sale price and the documented acquisition cost - with no 10% expense deduction.
The mitigation is in Art. 37a: a non-resident who is tax resident in an EU Member State, or in a state party to the EEA Agreement, may elect to have the final tax recomputed so that the amount due is calculated as it would be for a resident. The election covers all Art. 37 income for the year, not selected items.
For British and other non-European clients that election is not available - a circumstance that affects structuring more than the rate itself does.
The tax is 10%, but it is charged on 90% of the net annual result, because Art. 33(3) of the Personal Income Tax Act provides a 10% deduction for expenses. The effective rate is 9%.
Per transaction: sale price less acquisition cost for each transaction, the sum of gains less the sum of losses for the year, then a 10% expense deduction.
Under Art. 33(4), the weighted average price, where it cannot be proved which part is being sold.
No. The liability arises with the annual tax return.
Yes. DAC8 applies from 1 January 2026 and 2026 is the first reporting year; CARF has been in force for Bulgaria since 22 April 2026.
See also our guides to the Bulgarian CASP licence and MiCA in Bulgaria after 1 July 2026, and our crypto and blockchain practice.
This article reflects the Personal Income Tax Act as amended in ДВ issue 30 of 27 March 2026 and the position as at 19 August 2026. It is general information and does not constitute tax or legal advice. Prepared by the legal team at YARD Law Co., a law firm based in Sofia, Bulgaria.
Crypto income to declare in Bulgaria?
Regime assessment, computing the base, trader or investor, non-residents and the Art. 37a recomputation.