Four jurisdictions · 2026
Romania against
three neighbours.
A genuine comparison, not a case for Romania. Enter turnover, margin, and whether profit is extracted annually or left to compound, and see the effective burden across Romania, Bulgaria, Cyprus and Estonia side by side. Three of the four repriced within the last eighteen months — figures below are verified against primary and professional-firm sources, not carried over from an older comparison.
Lowest effective burden
Romania
—
All four, side by side
| Jurisdiction | Corporate | Dividend | Total | Effective |
|---|---|---|---|---|
| Romania— | €0 | €0 | €0 | 0% |
| Bulgaria10% CIT flat | €0 | €0 | €0 | 0% |
| Cyprus15% CIT, domiciled resident | €0 | €0 | €0 | 0% |
| Estonia0% retained, 22% distributed | €0 | €0 | €0 | 0% |
Method and assumptions
- Romania — 1% of turnover under the microenterprise regime where turnover is at or below €100,000 and at least 1 full-time employee is in place; otherwise 16% standard CIT on profit. Dividends, where distributed, carry 16% withholding. CASS on the shareholder is not modelled here — use the dividend tax calculator for that.
- Bulgaria — 10% flat corporate income tax, no turnover-based regime, no employee condition. Dividends carry a 5% final withholding tax under the Personal Income Tax Act. A proposal in the draft 2026 State Budget Act to double this to 10% was withdrawn on 2 December 2025 after public protests, and early parliamentary elections were called for 19 April 2026 — treat the 5% rate as live political risk, not settled law. Bulgaria adopted the euro on 1 January 2026.
- Cyprus — 15% corporate income tax from 1 January 2026 (up from 12.5%, aligning with OECD global-minimum rules). The table models a Cyprus-domiciled resident shareholder, who pays 5% Special Defence Contribution on dividends from profits earned after 1 January 2026 (cut from 17%). A non-domiciled Cyprus tax resident instead pays 0% SDC on dividends for 17 years from taking up residence — a materially better outcome not shown as the default row above. The Cyprus IP box, exempting 80% of qualifying patent, copyrighted-software and similar IP profit, produces an effective rate near 3% on qualifying income under the OECD modified nexus approach; it is not modelled here because it depends on qualifying R&D activity the inputs above do not capture.
- Estonia — 0% corporate income tax on retained profit; on distribution, tax is 22/78 of the net amount paid, equivalent to 22% of the gross profit distributed, modelled here as 22% of profit when the "distributed annually" option is selected. The reduced 14/86 rate for regular distributions was repealed from 2025. A temporary defence tax was scrapped by the Riigikogu on 19 June 2025 before taking effect, and a planned rise to 24/76 for 2026 was cancelled in December 2025.
- All four figures assume the shareholder is tax resident in the same jurisdiction as the company and ignore double-tax-treaty relief, foreign tax credits, and the founder's home-country position entirely.
- Out of scope throughout: substance requirements, controlled-foreign-company attribution in the founder's country of residence, place-of-effective-management challenges, and Pillar Two top-up tax for groups above the relevant consolidated-revenue threshold. These typically matter more than the headline rate and require professional advice specific to where the founder actually lives.
- Non-Romanian figures verified by web search against PwC Worldwide Tax Summaries, BDO, and national tax-authority sources on 2026-07-26. Romanian figures from
tax-rates.ts, verified 2026-07-22.
An estimate, not advice. Jurisdiction selection is a residence question before it is a tax question, and three of these four rates changed within the last eighteen months. Confirm the current position and the substance and CFC analysis for your own residence before you incorporate anywhere.
The part rates don't show
The lowest rate
is not the question.
All four jurisdictions implement the EU Anti-Tax Avoidance Directive, including controlled foreign company rules and exit taxation — and so does every other member state, which is where the exposure usually sits. A founder resident in Germany, France or the Netherlands who owns a low-tax company abroad may find its income attributed back to their home country under that country's own CFC rules, with the foreign rate serving only as a credit. The structure does not fail because the wrong jurisdiction was chosen. It fails because the founder never left home.
Place of effective management compounds this: a company registered in one jurisdiction but directed entirely from another is, on most treaty tie-breakers, tax resident where it is actually run. That applies identically to a Romanian SRL, a Bulgarian EOOD, a Cypriot limited company, and an Estonian OÜ. None of the figures on this page substitute for that analysis, which turns on the founder's residence, not the company's.
Fuller treatment in the jurisdiction comparison piece.
Disclaimer
These are indicative figures, not a filing position and not investment or relocation advice. They ignore substance requirements, controlled-foreign-company attribution, treaty relief, and Pillar Two exposure — each of which can change the answer more than the headline rate does. Non-Romanian rates were verified against the sources cited in the methodology block above as of 2026-07-26; confirm the current position before acting, since three of these four jurisdictions repriced within the last eighteen months.