Country profile
Country profile · Legal position 08/2026
Bulgaria: crypto taxes when leaving Germany
Destination Bulgaria: holding period, tax rate, classification under section 2 AStG, exit taxation and the five scenarios from the year of departure to a return to Germany.
The essentials
- Leaving Germany does not by itself trigger German tax on crypto held as private assets. It is different for business assets (section 16(3a) EStG) and shares in a company (section 6 AStG). Whether section 2 AStG or the destination country's law then applies depends on the individual case.
- Holding period: None; no threshold
- Regular rate on crypto gains: 10 % flat tax; because of the statutory cost deduction of 10 %, the actual burden is around 9 %. Mining: 15 %
- Classification under § 2 AStG: Yes* (low-tax country). *Own calculation or view discussed in the literature, no final official confirmation
- Crypto exit tax: Not known
At a glance
| Holding period | None; no threshold |
|---|---|
| Regular rate on crypto gains | 10 % flat tax; because of the statutory cost deduction of 10 %, the actual burden is around 9 %. Mining: 15 % |
| Classification under § 2 AStG | Yes* (low-tax country). *Own calculation or view discussed in the literature, no final official confirmation |
| Crypto exit tax | Not known |
| Inheritance tax treaty with Germany | No |
| Registration after the move | No reliable finding on a deadline or penalty for a separate registration |
| Tax residency certificate | Generally issued within about a month; applying is only recommended once the 183 days have actually been reached |
| DAC8/CARF | DAC8 reporting since 2026, first data exchange in 2027; no information on CARF |
Crypto taxation in Bulgaria
- Disposal and exchange: 10 % flat tax on gains, determined using FIFO, with no holding period and no threshold. Exchanging one cryptocurrency for another is also taxable; the exemption for shares on an EU/EEA-regulated market doesn't extend to crypto assets.
- Loss offsetting: The gains realized during the year less the realized losses are taxed, reduced by the statutory cost deduction of 10 %.
- Staking, liquidity mining, DeFi: So far, no express administrative guidance from the tax administration (NAP). The prevailing view in the specialist literature: acquisition value of zero leva, taxed at 10 % only on a later sale; a minority view instead argues for taxation at market value on receipt.
- Airdrops, hard forks: According to the prevailing view, captured only on sale, with an acquisition value of zero leva.
- Mining and systematic trading: In the view of the tax administration (NAP), mining counts as a commercial activity regardless of scale, as the income of a sole trader (registered or not): 15 % on the profit after operating expenses, declared in Appendix 2. The systematic trader who acts like a merchant in subject matter and scale falls under the same classification, even without registration.
- Declaration: Appendix 5 (code 508), deadline 30 April of the following year.
- VAT and records: No VAT on exchanging crypto assets for fiat money and vice versa (Hedqvist, ECJ). Keep documents for five years; without proof of acquisition cost, the tax administration can set it at zero.
- Wealth and inheritance: No general wealth tax. Spouses and direct descendants are largely tax-free, others pay 0.4 % to 6.6 %, depending on the municipality.
Classification under § 2 AStG
Bulgaria is a clear low-tax country within the meaning of § 2 AStG: at a reference income of €77,000, the Bulgarian burden of 10 % is clearly below the German figure of around 27 to 28 %, and the one-third threshold is clearly exceeded. Specialist sources cite emigration to Bulgaria as an example where “disputes with the tax authorities can arise.” Without substantial economic ties to Germany, § 2 AStG already fails at the third condition.
The five scenarios
Year of departure
- German unlimited tax liability only ends once residence and habitual abode are actually given up.
- In Bulgaria, tax residency arises for anyone who stays in the country for at least 183 days a year, has their center of vital interests there, or maintains a permanent home there and habitually resides there.
- If the German home has already been given up at the time of a crypto sale, the gain isn't domestic income under § 49 EStG. If both homes exist in parallel, the tie-breaker under the DTT applies: permanent home, then center of vital interests, then habitual abode.
First year after leaving
- 10 % on every realized gain, determined by FIFO, regardless of holding period; no tax-free basic amount.
- Example: Mr. Wittek (Sofia 2026, apartment given up, Bulgarian employer) sells Bitcoin bought five years earlier at a gain: in Germany it would have been tax-free, in Bulgaria a nominal 10 % applies (the effective burden is around 9 % because of the statutory cost deduction of 10 %). § 2 AStG plays no role for him; for a colleague who keeps her rented condominium in Frankfurt, this would need to be assessed differently.
More than ten years
- For crypto gains, nothing changes for income tax purposes. Extended limited tax liability can apply in the first years and ends ten years after the end of the year in which German unlimited tax liability ended. From then on, only ordinary limited tax liability remains, which requires a domestic source of income (current position).
- No inheritance tax treaty: for German nationals, German extended unlimited inheritance tax liability applies if the deceased or donor was fully taxable in Germany within the last five years before the inheritance. After more than ten years in Bulgaria, this window is closed.
Moving on to a third country
- According to available sources, Bulgaria has no exit taxation of its own for privately held crypto assets; moving on to a third country shouldn't trigger any tax there on unrealized crypto gains. Any continuing extended limited tax liability under § 2 AStG is reassessed annually.
Returning to Germany
- Moving back ends any extended limited tax liability automatically; re-establishing a residence or habitual abode brings unlimited tax liability back into effect. The original acquisition date still counts: if a position has been held for longer than a year in total, a later sale in Germany is tax-free under § 23 EStG.
Practical tip
Any position at a gain that has been held for more than a year at the time of emigration can still be sold tax-free in Germany (§ 23 EStG) and, while still resident in Germany, bought back at the current market value; the acquisition cost is thus stepped up tax-free before Bulgaria takes over the taxing right. Loss positions held for more than a year shouldn't be sold beforehand: that brings no benefit in Germany, while in Bulgaria the loss can be offset against other Bulgarian capital gains from the same year.
Show sources
- Convention between the Federal Republic of Germany and the Republic of Bulgaria for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital of 25 January 2010, in force since 2011: DTT
- Art. 33(4) ZDDFL (as in force since 1 January 2024): taxation of sale or exchange of financial assets including virtual currencies, netting of gains and losses, cost deduction of 10 %
- Art. 50 ZDDFL, Appendix 5 (code 508), deadline 30 April: declaration of income from selling or exchanging virtual currencies
- ECJ, judgment of 22 October 2015 – C-264/14 (Hedqvist): VAT exemption for exchanging crypto assets and fiat money
- Art. 50 ZDDFL (Appendix 2), Art. 26(7) ZDDFL, Art. 48(2) ZDDFL: declaration of mining income in Appendix 2, Art. 33 ZDDFL not applicable to merchants, rate of 15 % (the classification of mining as a commercial activity is the view of the NAP)
- Art. 1(3) Commercial Act: merchant status without registration
Questions about Bulgaria
Is there a holding period for crypto in Bulgaria?
None; no threshold. Details and exceptions are in the country profile on this page.
How high is the tax on crypto gains in Bulgaria?
10 % flat tax; because of the statutory cost deduction of 10 %, the actual burden is around 9 %. Mining: 15 %. Details and exceptions are in the country profile on this page.
Is Bulgaria a low-tax country under section 2 AStG?
Yes (low-tax country). Own calculation or view discussed in the literature, no final official confirmation. Details and exceptions are in the country profile on this page.
Does Bulgaria have an exit tax on crypto?
Not known. Details and exceptions are in the country profile on this page.
Responsible for content: Matthias Steger, German certified tax advisor (Steuerberater), author of "Krypto-Steuern und Auswandern" (in German).
Legal position: country data 08/2026 (status of the book). Sources are listed in the "Sources" section. The figures are abridged and are not advice on an individual case. The tax law of the destination countries and immigration law are outside our German advisory scope; we coordinate with local advisers. The § 2 AStG classification is our own calculation based on the 2026 tariff and is not an official ruling. Where this English text and the German text differ, the German text prevails.
Legal position: country data 08/2026 (status of the book). Sources are listed in the "Sources" section. The figures are abridged and are not advice on an individual case. The tax law of the destination countries and immigration law are outside our German advisory scope; we coordinate with local advisers. The § 2 AStG classification is our own calculation based on the 2026 tariff and is not an official ruling. Where this English text and the German text differ, the German text prevails.