Bulgaria: taxation upon transfer of real estates

Any income derived from use, sale, exchange or other transfer of immovable property, including any such transfer of an undivided interest in or a limited right in rem to any such property situated within the territory of the country, shall have its source inside the country - Art.8, paragraph 10 of the ITNPA. The taxable income accruing from the sale or exchange of immovable property, including of limited rights in rem to any such property, shall be determined by debiting the positive difference between the selling price and the cost of acquisition of any such property with 10 per cent expenses (Art. 33, paragraph 1 of the ITNPA). A final tax shall be levied on the following income from a source inside Bulgaria, charged/paid in favour of any non-resident natural person any income from sale, exchange or other onerous transfer of immovable property (Art. 37, paragraph 1, item 10 of the ITNPA). The income of local legal persons from such deals is included in their gross profit, which is subject to taxation under CITA. The taxable amount for assessment of the tax withheld at source on any income accruing to any non-resident legal persons from disposition of immovable property shall be the positive difference between the selling price and the documented cost of acquisition of the immovable property - Art. 199, paragraph 4 of the CITA.