One point of coordination for family assets and administrative matters, with regulated investment work handled by appropriately licensed providers.
A family asked ARG how to coordinate the different parts of their Bulgarian affairs. The challenge was not one isolated transaction, but the connection between ownership, banking, tax questions and planned activity.
ARG mapped those issues, brought the relevant evidence and advisers together, and organised the work around one plan. A common checklist helped the family follow progress without piecing together separate instructions. This service applies the same practical discipline while keeping a clear distinction between family-office coordination and regulated investment activity.
ARG can help when you need to
Specify who may instruct, sign, approve spending and receive reports. Professional tax, legal and regulated investment functions need named responsible advisers.
List property, accounts, shares, debts and guarantees, including those abroad. An inheritance decision must consider liabilities as well as the assets the family wants to retain.
Identify your residence facts, relevant countries and planned dates. Immigration status and the bank account’s location do not settle the tax treatment.
Identify every relevant entity and the natural persons who ultimately own or control it. Include representatives, voting arrangements and documents connecting the ownership chain.
A family office is an organisational arrangement for a family's affairs, not a single Bulgarian licence covering every professional activity. It can coordinate documents, reporting, property administration, tax advisers, lawyers and banking requests. The mandate should state who makes decisions, who may sign and which professional is responsible for each legal, tax or investment task.
Personal recommendations about particular financial instruments, discretionary portfolio management and receiving or transmitting investment orders can fall within regulated investment services. The MiFID II definitions and Annex I distinguish these activities from general administration. Calling the work family-office support, charging it within a broader package or obtaining a wide power of attorney does not automatically create an exemption. Where an authorisation or a precisely applicable exemption is needed, that must be established before the activity begins. MiFID II: definitions and investment services.
Keep client assets with the appropriate bank or custody provider under the proper mandate. Identify which instructions require the owner, which need two approvals and what happens during incapacity, travel or a family dispute. A consolidated asset report should distinguish legal ownership, market estimates, borrowing, restrictions and available cash. An estimated property value is not money available to meet next month's tax liability.
ARG can coordinate a practical responsibility map, document requests and the handover between professional advisers. Agree a calendar for recurring returns, corporate decisions, lease renewals, insurance and bank updates, with a named owner for each task. Record decisions and supporting advice so the family can see why an action was taken and which facts would require it to be revisited. This creates continuity without suggesting that one coordinator exercises every regulated professional function.
Article 2(1)(k) of MiFID II contains a specific exclusion for investment advice provided in another professional activity outside the Directive where that advice is not specifically remunerated. It is not a general permission for a family office to sell investment recommendations within an undifferentiated fee. The actual professional activity, advice, remuneration and other services must fit the exclusion. It does not automatically cover portfolio management, executing orders or custody. Record the proposed activities and fee structure for the regulatory assessment before describing a mandate as exempt.
An SPV, or special-purpose vehicle, describes a company organised for a defined asset or project. It is not automatically a separate Bulgarian legal form or an investment licence. A privately owned EOOD or OOD holding a property should not be confused with a regulated special-investment-purpose company or a fund. The intended activity, sources of capital and services supplied to others determine whether additional regulation is relevant.
When the company buys an asset, the company becomes owner. The shareholder owns shares, not the company's apartment or bank account directly. This can make co-investment, management and transfer of ownership interests easier, but it introduces company accounts, decisions, filings and a separate tax position. Limited liability is not an assurance that the asset is protected from the company's own creditors or a shareholder's personal guarantees. Registry Agency: company registration.
Before incorporation, decide who owns the shares, who manages, which decisions require investor consent and how capital enters and leaves. Distinguish paid-in capital, shareholder loans, third-party finance and distributions. Record beneficial ownership through the whole control chain. A nominee or foreign parent does not remove disclosure obligations or a bank's need to understand the natural persons who ultimately own or control the structure.
Compare an asset sale with a share sale, personal use with commercial letting and the consequences of death or disagreement between investors. Funding and exit documents should address those scenarios before the asset is acquired. ARG coordinates the corporate, property and accounting work with the relevant professionals. The structure should solve a defined ownership or governance problem at an acceptable ongoing cost; the label SPV alone gives neither tax relief nor unrestricted access to every category of Bulgarian land.
Tax residence is a factual and legal classification, not simply nationality, immigration permission or ownership of an apartment. Article 4 of the Bulgarian Personal Income Tax Act considers the statutory residence criteria, including presence for more than 183 days in a twelve-month period and the centre of vital interests. A Bulgarian permanent address does not make a person resident where the centre of vital interests is outside the country under the Act's exception.
The centre-of-interests assessment considers family, property, work or business and where the person manages their assets. Collect the actual facts: travel dates, home availability, employment, family location and management activity. A residence certificate supports a position but should correspond to those facts. Do not assume that spending fewer than 183 days in one calendar year automatically settles every domestic or treaty question. NRA: tax-residence criteria.
If two countries treat you as resident, the relevant double-tax treaty may apply a tie-breaker sequence. The exact treaty, income article and relief method must be checked for the countries involved. Bulgarian tax residents generally face taxation on worldwide income under the applicable rules, while nonresidents are assessed on relevant Bulgarian-source income. A foreign bank account does not by itself take income outside the Bulgarian analysis.
Plan the year of relocation before a major distribution, sale or retirement payment. Identify when income is legally acquired, which country can tax it, what was withheld and what evidence supports relief. ARG coordinates the facts with tax advisers in the relevant jurisdictions so returns and bank self-certifications use a coherent residence position. The objective is to claim the correct relief with evidence, not to change labels while the underlying life and business remain elsewhere.
A relocation chronology should distinguish physical arrival, availability of the family home, commencement of work and the dates of major receipts. Those events may fall in different months and need separate evidence rather than one assumed “move date”.
Customer due diligence, often called KYC, means identifying and verifying the client, understanding the purpose of the relationship and assessing the activity expected through it. Bulgarian banks apply these duties under the Measures Against Money Laundering Act, known as ЗМИП. A passport answers who you are; it does not explain why the account is needed or whether the proposed transactions fit your circumstances.
Prepare a current identity document, address information, tax-residence details and a concise description of your employment, business or investment activity. Explain the Bulgarian connection: relocation, ownership of a local property, business operations or another genuine purpose. Give realistic expected volumes, currencies, countries and counterparties. A newly opened account expected to receive the proceeds of a company sale needs a different explanation from an account used for ordinary household expenses. Bulgarian Measures Against Money Laundering Act.
Where somebody acts for you, the institution also identifies the representative and checks their authority. A company must establish its existence, representatives and beneficial owners. The beneficial owner is ultimately a natural person; an ownership chart ending at another company leaves the central question unanswered. Control through voting arrangements or other means can matter alongside percentage ownership.
ARG helps organise a consistent account of these facts and the supporting records. The bank determines its acceptance process and whether remote identification is available for your profile. Ask about document language, originals and any appointment before making travel plans. Give the same accurate residence and ownership information throughout the file and explain legitimate differences between your residential address, correspondence address and tax residence.
Keep the underlying evidence, not only the explanation submitted for one appointment. A property sale, dividend, inheritance distribution or company restructuring may be relevant again when the funds are reinvested or transferred. The completion file should show who owned the asset, the legal event, the amount received, any tax treatment and the subsequent account movements.
Separate historical evidence from details that need refreshing. An old acquisition deed may remain essential, while an identity document, residence certificate, company extract or authority to act may need an updated version. Keep a dated ownership chart and record changes to control, addresses and tax residence. Do not assume that a file accepted by one bank will be accepted unchanged by another institution or for a different transaction. Bulgarian Measures Against Money Laundering Act.
Article 67 of the Bulgarian AML Act places record-retention duties on obliged institutions, generally for five years with statutory rules governing the starting point and possible extensions. This is not a direction for an individual to destroy original title, tax or succession records after five years. Those documents may serve different legal purposes for much longer. Retention decisions should reflect the type of record, the responsible person and applicable duties.
Use secure, controlled access and identify who may share documents with a bank, notary, accountant or legal adviser. Where a family member coordinates the administration, provide the necessary authority rather than sharing account passwords. ARG can organise an indexed handover and an update list so future requests can be answered from an accurate record. The client remains able to see which originals exist, where they are held and which items still need clarification.
Tell us where you live, how your business works and what you want to change. We will help you identify the questions to resolve and the next steps to consider.
A portfolio can produce dividends, interest, capital gains, distributions, redemptions and income from cryptoassets. These categories can have different tax bases, exemptions, acquisition dates and reporting routes. The broker's single profit figure may combine realised and unrealised changes, fees, currencies and returns that Bulgarian law treats differently. Start from the underlying transactions, not from the amount withdrawn to your bank.
For financial-asset disposals, Article 33 of the Personal Income Tax Act provides the relevant calculation framework for an individual outside the business regime. Article 13 contains exemptions for specified financial-instrument transactions meeting the statutory conditions. An instrument being listed somewhere, or an app describing it as an ETF, does not automatically establish that the actual disposal occurred on a qualifying market or within another permitted exemption. NRA: disposal income and exemptions.
Retain acquisition and disposal confirmations, asset identifiers, trading venue, dates, quantity, price, fees and currency information. Transfers between your own brokers need a carried-forward cost record. Corporate actions, inherited or gifted assets and a missing acquisition price can require a different calculation. Cryptoasset records should distinguish purchases, disposals, exchanges and transfers between wallets you own; a wallet transfer and a sale are not the same event.
For cross-border income, obtain foreign withholding evidence and test the applicable treaty and Bulgarian relief route. A tax paid overseas is not automatically creditable in any amount or against any Bulgarian liability. ARG coordinates the transaction history and the professional tax analysis before a planned exit or distribution. The deliverable should identify taxable events, available exemptions and evidence needed for the return, while preserving the separate investment decision for the client and appropriately authorised adviser.
A company's bank balance belongs to the company. A shareholder needs a lawful basis for receiving money: a dividend, remuneration, loan repayment, reimbursement or another properly documented transaction. Each has different corporate, accounting and personal-tax consequences. Describing a transfer as an owner's withdrawal does not determine its treatment.
For individual dividend income, the Bulgarian Personal Income Tax Act provides a five-percent final-tax rate under Article 46(3), subject to the relevant domestic and treaty analysis. The supplementary definition of dividend also connects to concealed profit distribution. Payments to an owner or related person that do not reflect a genuine business purpose or market terms can therefore require review even where no formal dividend was declared. NRA: dividend definitions and tax.
Before distributing, confirm the available distributable result, the competent corporate decision and any restrictions arising from financing or the company's position. The company and the individual have different tax and reporting responsibilities. A Bulgarian-resident individual's foreign dividend may require personal reporting even though a Bulgarian company ordinarily handles withholding on its own distribution. Preserve gross amounts and foreign tax evidence, not only the net bank receipt.
For the bank file, connect the shareholder's ownership to the company accounts, distribution decision, tax treatment and payment. For a shareholder loan, keep the original loan agreement and movements showing that the amount repaid was actually advanced. ARG coordinates these records with the accountant and legal adviser so that the source-of-funds explanation and financial statements agree. This is especially useful before a property purchase: the company may have sufficient cash while the individual has not yet lawfully received funds available to complete.
A gift transfers value without repayment; a loan creates an obligation to repay; inheritance arises because of death. These legal causes should match both the documents and the parties' actual intention. A transfer reference saying “family support” does not by itself establish which rules apply. This matters for municipal gift tax, bank evidence, the donor's estate plan and the recipient's later sale of an asset.
Under the Bulgarian Local Taxes and Fees Act, gifts between spouses and relatives in the direct line are exempt from gift tax. Direct line means, for example, parent and child or grandparent and grandchild. It does not automatically include siblings, cousins, an unmarried partner or a company owned by a family member. For taxable gifts, the municipality applies the legally permitted rate and valuation rules. A gift of real estate must also meet the required conveyancing form and registration procedure. NRA: gift-tax rules.
Prove the qualifying relationship with civil-status records, including the complete chain where a grandparent or a name change is involved. Establish any authentication and translation needed for foreign documents. A tax exemption does not eliminate notarial, registration or other transaction expenses. The inheritance-tax regime is separate and must be assessed against the heirs, assets and applicable rules rather than assuming all transfers within a family are identical.
For a loan, document the lender, borrower, amount, disbursement, repayment terms and any interest, then consider relevant tax-reporting duties. For a gift, preserve the donor's funding evidence as well as the recipient's receipt. ARG coordinates the choice and documentation with the professional adviser before the transfer, so the bank explanation, tax treatment and family plan describe the same transaction.
Succession concerns the transfer of a deceased person's assets, rights and obligations. Where Bulgarian succession law governs, children and a surviving spouse are central to the statutory order; the precise shares depend on the relatives surviving the deceased. An unmarried partner does not acquire the status of a spouse merely by sharing a home. Before choosing beneficiaries, map the family relationships and establish which assets actually belong to the person making the plan.
The Bulgarian Inheritance Act recognises handwritten and notarial wills. A handwritten will must be written entirely by the testator, dated and signed, with the signature after the dispositions. A typed document signed at the bottom is not thereby a valid Bulgarian handwritten will. A notarial will follows a prescribed procedure involving the testator, notary and two witnesses. A power of attorney is not a substitute for the testator making their will. Bulgarian Inheritance Act.
Distinguish leaving the whole estate or a fraction of it from leaving a specific asset. The Act treats universal dispositions and particular legacies differently, including the beneficiary's legal position. Identify the asset accurately and consider what happens if it is sold or the intended beneficiary dies first. An alternative beneficiary can be useful, but a clause ordering one heir to preserve and pass the inheritance on at their own death raises separate statutory limits.
ARG coordinates the family and asset information with the lawyer and notary. Bring existing wills from every country, earlier gifts, marriage records, ownership documents and the intended distribution. Agree how the original will is held and located. A carefully drafted document still needs a practical discovery and implementation plan after death, especially where beneficiaries do not live in Bulgaria.
Regulation (EU) 650/2012 separates the place where an asset is located from the law governing succession as a whole. Under Article 21, the usual connecting factor is the deceased's habitual residence at death, subject to the Regulation's exceptions. Habitual residence reflects the person's actual life; it is not automatically the address printed on a permit or a simple tax-day count.
Article 22 permits a person to choose the law of a nationality they hold when making the choice or at death. A person with several nationalities can choose one of those national laws. The choice must satisfy the Regulation's requirements and should be coordinated with existing wills. It is not a general freedom to choose whichever country's succession rules seem most attractive. Under Article 20, the relevant law can be that of a non-EU state. Regulation (EU) 650/2012.
The Regulation does not determine inheritance tax, matrimonial-property ownership, the creation and administration of trusts or all company-law consequences. Bulgarian property-registration requirements also remain relevant. A nationality-law choice therefore cannot be assumed to remove every Bulgarian formality, land restriction or tax obligation.
Prepare a country-by-country estate map showing citizenship, habitual residence, family, property, accounts, companies and existing testamentary documents. Consider which authority can issue the documents the heirs will use, and whether a European Certificate of Succession is appropriate for a participating-state cross-border case. It provides evidence of relevant status and powers; it does not create a universal exemption from local registration requirements. ARG coordinates the Bulgarian information and professional advisers in the other relevant jurisdiction so a new document supports, rather than accidentally revokes or contradicts, the wider estate plan.
A foreign owner adds a chain of legal capacity and control to the property vehicle. Establish the foreign entity's current existence, legal form, registered representation and authority to invest. Obtain the relevant constitutional documents and decisions, not just a certificate naming the entity. Where several companies intervene, follow the chain to the natural persons who ultimately own or control it and explain any control that does not follow ordinary share percentages.
Bulgarian anti-money-laundering rules require identification of beneficial ownership, including the relevant people behind trust and similar arrangements. A settlor provides the assets, trustees administer them, a protector may hold supervisory powers and beneficiaries receive or may receive the benefit; other persons can exercise ultimate control. A chart showing only a trustee company can therefore leave essential parts of the control and benefit structure unanswered. Bulgarian Measures Against Money Laundering Act.
The foreign trust's treatment in its home jurisdiction does not by itself decide Bulgarian ownership, registration, tax or succession consequences. Identify who will be named as owner of the Bulgarian company interest, who signs, which law governs the arrangement and what powers permit the proposed acquisition or distribution. Provide the trust instrument or appropriate extracts and supporting professional documentation through a controlled disclosure process when required.
Compare the same structure across the company register, bank onboarding, tax analysis and succession plan. Differences should be explained rather than concealed by different simplified charts. ARG coordinates document requests with the foreign advisers and Bulgarian legal partner. The objective is a structure that the relevant institutions can understand and administer, with a clear account of authority, economic benefit and future changes, rather than assuming that a foreign label automatically creates a recognised Bulgarian property or tax outcome.
A Bulgarian power of attorney, пълномощно, allows another person to act in your name within the authority you grant. It does not transfer ownership to that representative. For a property transaction, the form of the authority and its certification must satisfy the requirements for the intended act. Agree the draft with the Bulgarian professional handling the transaction before signing it abroad; a general overseas notarisation may not provide the required certification of both signature and content.
Define the transaction, the property, the permitted price or price limit, payment destination and the actions the representative may take. Decide expressly whether they can amend the contract, receive money, borrow, mortgage, appoint another representative or contract in a potentially conflicting capacity. A wide authority may be convenient but exposes you to commitments you did not intend. A narrow authority can fail if it omits an essential registration or declaration. Notaries and Notarial Practice Act.
Foreign execution requires a country-specific route for authentication and translation. A treaty may remove an apostille requirement; in other cases an apostille or consular legalisation is needed. These formalities authenticate documents or signatures, not the commercial wisdom of the transaction. Arrange originals and certified translations within the completion timetable.
Before use, check that the authority remains effective and has not been revoked. Changes to the property, seller or price may require a new document. ARG coordinates preparation and transmission with the relevant lawyer and notary and keeps the client's substantive decisions separate from the representative's administrative work. Banking providers may require their own mandate or personal identification even where the property signing can proceed by proxy.
Build the calendar by taxpayer and legal event. A person, their holding company and a jointly owned property do not share one tax return merely because they belong to the same family. Record the owner, income type, responsible adviser, evidence required, filing deadline and payment account. Include a date for receiving the documents, so a deadline is not the first day anyone asks the foreign broker or property manager for information.
For an individual's ordinary rental income, the NRA guidance identifies quarterly advance-tax duties and the annual return, with a special fourth-quarter withholding election where applicable. These dates should be coordinated with company reporting and foreign obligations, not treated as one universal 30 April deadline. Property acquisitions, gifts and succession can create event-based local obligations with their own rules; they need an entry when the event occurs rather than waiting for the personal income-tax season. NRA: rental-income rules.
Separate a statutory deadline from a family decision. A dividend may require an approved distribution and available funds; an asset sale may require enough time to establish acquisition cost and obtain foreign tax evidence. Give each adviser the same transaction chronology, residence facts and ownership map. Where one country taxes income that another exempts or credits, record the relief mechanism and supporting documents instead of assuming that a payment abroad eliminates Bulgarian reporting.
ARG coordinates the family administration, follows up missing evidence and records who has approved, filed and paid. Require completion receipts and reconcile payments with liabilities. Revisit the calendar after a relocation, marriage, death, company reorganisation or new rental activity. This allows the family to use available relief and maintain continuity without asking a single member to remember every professional's deadline or circulate passwords for everyone else's accounts.
Compare the related procedures in this category, including their requirements and the stage at which you need them.
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