The rules regarding Controlled Foreign Companies (CFC) do not apply in Bulgaria  [ Controlled Foreign Company (CFC) Rules – Правила за контролирани чуждестранни компании (CFC) ]  to taxation on tax resident individuals

The various rules against tax avoidance practices that directly affect the functioning of national markets are outlined in Council Directive (EU) 2016/1164 , also known as  the Taxation Directive  or  the Tax Avoidance Directive , adopted on 12 July 2016. 

On 11 November 2018, the Bulgarian Parliament adopted amendments to the Corporate Income Tax Act pursuant to Council Directive (EU) 2016/1164.

SPECIFIC RULES FOR DETERMINING THE TAX FINANCIAL RESULT IN THE CASE OF A FOREIGN CONTROLLED COMPANY are contained in Chapter Nine “a” (Articles  47в. to 47д.) of the Law on Corporate Income Tax – Закон за Корпоративното Подоходно Облагане (ЗКПО).

On the other hand, no provisions regarding Controlled Foreign Companies (CFCs)  have been introduced in the  Law on Income Taxes of Natural Persons – Закон за Данъците bърху Доходите на Физическите Лица (ЗДДФЛ) .

Please note that  in Bulgaria the tax rate on foreign-source dividends distributed to a tax resident individual is 5% (5 percent) with the possibility of fully deducting the amount withheld abroad as withholding tax.
Therefore:

• If the tax paid abroad is higher than or equal to 5%, no tax is due in Bulgaria;
• If the tax paid abroad is less than 5%, only the balance up to 5% is paid in Bulgaria.

See: Bulgaria – 5% tax rate on foreign-source dividends distributed to a tax resident individual with the possibility of fully deducting the amount withheld abroad as withholding tax

Therefore, in Bulgaria, even in the case of a Tax Resident Individual who controls a foreign company classified as a Controlled Foreign Company (CFC), the tax rate on foreign-source dividends distributed to the tax resident individual is 5% (5 percent) with the possibility of fully deducting the amount withheld abroad as withholding tax.