Pillar Two in Bulgaria: Ministry of Finance ruling provides much‑needed interpretative guidance

On 14 April 2026 the Bulgarian Ministry of Finance published a non-binding tax ruling addressing several key questions related to the application of the OECD Pillar Two rules in Bulgaria. The ruling is of particular relevance for in‑scope multinational enterprise (“MNE”) groups, given the limited administrative and interpretative practice available to date in this area.

The guidance provides an important reference point for taxpayers, as it outlines Bulgarian position on a number of practical aspects of the global minimum tax framework. As such, it may serve as a useful basis to be taken into account when performing QDMTT calculations, assessing potential top‑up tax exposure and preparing for local compliance obligations in Bulgaria.

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