Company in Bulgaria for software devs

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Indeed proper planning and structuring is required but Cyprus service providers (lawyers, auditors, tax consultants) are very cost-effective considering other jurisdictions. Also, the fact that the OP is involved in software development and therefore could fall under the IP Box Regime in Cyprus (i.e. tax rate is decreased to 2.5% on income deriving from qualifying IP assets) it would be unreasonable to not at least consider the option of Cyprus. Noting that as a non - dom he would be exempted from tax on dividend.
 
I totally agree that Cyprus is a great option comparing to _higher_ tax jurisdiction.
However, I do think that the OP has an easy and safe option has a 10+4.5% tax base, so, personally I would take that.
If he wants to take a risk (and it is a risk that a non dom status in Cyrpus doesn't remove), I would just go full nomad and just pay the 10% tax in Bulgaria.
Again, Cyprus is a good option in general, and it is worth the hassle and the cost in ( 3000/4000 per year ) in many cases, just, in my opinion, not worth considering in this very specific case, giving the easy alternative.
 
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