So, in summary, what you are doing is illegal, but --according to your lawyers-- hard to trace or currently unenforced in Bulgaria.
If you ask me, I'd rather say "yes", but rather "impossible" than "hard" to trace.
But I am not a lawyer. And because usually it's me the overly concerned about things being 100% clean, I asked multiple times all the lawyers and the accountant - "is this legal?" and all of them said confidently, without even a second though "yes".
As I mentioned, when it comes to the "legal" definition, my understanding is that in law, it's much more important to see the practice of how the law is interpreted and applied than how is written. There is a legal term for this, English is not my native language, but in essence it means looking through all the law cases who regarded similar matters and to see their outcomes.
For example, when I mentioned to Gibraltar and BVI lawyers I will get a full power of attorney from the Nominee Director and distribute the dividends myself and do everything as if I was the director, they said, wait a minute, if you do this obviously you will be perceived as the director yourself, this will not hold. When I asked my BG lawyer about it, he said, if you wish, I will send you the link to all the law case outcomes regarding similar things to see yourself - there is simply not such a case in the entire history.
I can understand where you are coming from and I was asking many questions as well, at some point I gave up as I felt I am the weird one in this situation. I figured if the mass practice is this to be done and not even investigated, why even bother changing the law? There is a difference between killing someone and hoping you won't be found, and doing something about which everyone, including the authorities, know they will not even try to find out. For example, a reputable accountant would not give with a huge confident smile on a public youtube interview an advice to kill someone and hide, but she obviously gives a clean professional advice for doing this offshore setup. On an interview, which can be obviously viewed by the TAX authorities. And if they wish they could dig at least into her clients.
When it comes to "untraceable" it's not Bulgaria though. Yesterday I discussed with a Maltese accountant the setup of Maltese company + Portuguese NHR (
here). It obviously relies as well on being untraceable. And the accountant claimed he knows and works with multiple Portuguese lawyers, who have confirmed this setup is fine.
That's why I asked on so many other topics, how do other countries find out about the offshore business when they don't have the authority to inspect it? I still have no clear answer. So my understanding is that what is untraceable as per law has other means for being faught against. For example, in Portugal they tax 35% dividends from tax havens, even if you have NHR. In countries with strict CFC rules, being a natural person tax resident is enough to make your offshore company tax resident as well. That's a good example for measures about such setups - if they can't trace it (I still don't understand how they could), they would do something else about it.
In Bulgaria... the parliament in a funny scandal accepted the CFC law (I think in the first place they accepted it only because they were forced to do it by the EU) with a ridiculous mistake "not on purpose": that it covers only low-tax, but not zero-tax jurisdictions. Later they were forced by the EU to fix that and they fixed it it but they still left CFC rules to apply only for companies and not for natural persons. This should speak enough about their intentions and the "spirit of the law" in Bulgaria when it comes to this.
