Inheritance and succession in Bulgaria

Which country's inheritance law applies?

Bulgaria participates in EU Regulation 650/2012 on cross-border succession. The starting rule for a person whose last habitual residence is in Bulgaria is normally the law of that state for succession. The regulation permits a person to choose the law of their nationality, including a non-EU nationality, in a clear disposition such as a will. For a British national, the relevant law within the UK depends on the person's connections to England and Wales, Scotland or Northern Ireland.

Because the UK is not bound by the EU Succession Regulation, recognition, estate administration, land registration and ownership rights on each side require coordinated professional planning. Neither residence in Bulgaria nor a UK will automatically makes all Bulgarian inheritance rules disappear. EU cross-border succession overview ↗.

UK wills, Bulgarian wills and accidental revocation

Bulgarian law recognises handwritten and notarial wills with specified formalities. A handwritten Bulgarian will must be entirely handwritten, dated and signed; a notarial will is drawn up with formal witness requirements. Bulgarian law does not permit joint wills made by two individuals.

People with property in both countries may use coordinated wills, but making a second will can accidentally revoke or contradict an earlier will. Obtain written advice about language, formal validity, choice of law, executors, local registrations, translations, apostilles and how any UK grant of probate will be used abroad. Do not copy a standard UK wording onto Bulgarian property documents.

Where a Bulgarian handwritten will covers immovable property, its publication and registration requirements can matter after death. A solicitor and Bulgarian notary should align both estates. EU e-Justice: Bulgarian wills and succession ↗.

Forced heirship and protected reserved shares

Under Bulgarian Succession Act Articles 28–29, applicable Bulgarian succession law reserves portions for specified close relatives. A bequest or lifetime gift cannot necessarily defeat those claims. These examples apply where Bulgarian law governs the succession; family circumstances and the applicable law change the result.

These figures apply to a relevant estate after assessing property ownership, obligations and certain gifts. They cannot be applied to a house's full market price without checking what actually belonged to the deceased. Official Bulgarian succession summary ↗.

Joint names, fractional shares and marriage

Being named on a Bulgarian notarial deed with your partner does not by itself prove that the surviving owner automatically inherits 100% as under an English joint tenancy. Bulgarian co-ownership commonly includes defined ideal shares (идеални части). Married couples may also have matrimonial community property depending on their regime and when/how property was acquired.

Ask a Bulgarian property lawyer to explain the existing deed and marital-property position before planning a will. Inheritance to several children can produce multiple co-owners who later need voluntary or judicial division.

When an owner dies: the practical process

1. Obtain the death certificate and, where needed, certified copies, legalisation/apostille and Bulgarian translation.
2. Secure the property, mortgage records, utility bills, land documents and all wills; identify heirs and any cross-border assets and liabilities.
3. Ask the Bulgarian lawyer and notary which authority must publish and register a will, and whether the deceased's details allow a municipal certificate of heirs (удостоверение за наследници).
4. Establish who may accept or renounce the inheritance, whether a court filing is required and whether acceptance by inventory is appropriate to limit liability for estate debts.
5. The Bulgarian e-Justice guidance describes an inventory-acceptance filing within three months of learning of the succession, potentially extended by a further three months. Ask the lawyer immediately; do not assume it is a general deadline for every ordinary inheritance.
6. Update the appropriate property-register entries and resolve mortgages, municipal obligations, co-owner division and any UK probate or IHT reporting separately.

The Bulgarian estate process is not invariably the same as obtaining an English grant of probate. Heirship evidence, notarial publication, property registration and potential court proceedings can be separate steps. e-Justice procedures ↗.

Inheritance tax and gifts across generations

Bulgaria's Ministry of Finance states that surviving spouses and direct-line heirs do not pay Bulgarian inheritance tax. For other categories, the municipality sets rates: siblings and siblings' children are generally subject to 0.4–0.8% and others 3.3–6.6%, each applied to the relevant taxable inheritance slice above €127,822.97 under the published framework. Confirm the current municipal ordinance and exemptions. Where taxable, a municipal inheritance declaration is generally due within six months of the succession's opening; do not presume this applies unchanged to exempt direct-line heirs.

Gifts between spouses and direct-line relatives have separate local-tax exemptions, but notarial costs, title formalities and potential UK tax treatment still require checking. Bulgarian inheritance tax ↗; Bulgarian gift tax ↗.

UK exposure: since 6 April 2025, UK Inheritance Tax treatment of overseas assets depends principally on long-term UK residence, with special transition and post-departure rules. Someone resident in the UK for at least 10 of the previous 20 tax years may remain within scope after leaving, potentially for years. This is entirely separate from the UK–Bulgaria income and gains treaty. HMRC long-term residence and IHT ↗.

What changes under the UK's April 2025 Inheritance Tax rules?

For deaths and relevant transfers from 6 April 2025, UK inheritance-tax exposure on overseas assets is primarily tested under long-term UK residence, rather than the former general domicile test. HMRC's normal test looks at UK tax residence in 10 or more of the previous 20 tax years, with special transitional exceptions. A person may remain within the rules for three to ten tax years after leaving, depending on their past UK residence history. A Bulgarian home is not automatically outside UK inheritance-tax consideration simply because the owner or family has moved abroad.

Example for research, not a tax assessment: if British owners move to a village in Bulgaria and one dies two years later, the estate can still need a UK long-term residence/IHT review even where a surviving spouse or direct-line heir is exempt from Bulgarian inheritance tax. Separate Bulgarian property registration, estate administration and UK reporting may still be necessary.

Have a qualified cross-border adviser identify the correct UK tax years, exemptions and asset location, and check inheritance/gift rules for the specific beneficiaries. Do not apply the UK–Bulgaria income-tax treaty as if it automatically removed inheritance tax. HMRC: current long-term UK residence rules for IHT ↗.

What to arrange while both owners are alive

1. Ask the notary for current title deeds and exact ownership shares, including each garden and agricultural parcel.
2. Obtain a Bulgarian legal opinion on succession law, reserved heirs and any choice-of-law clause.
3. Have UK and Bulgarian wills reviewed together, including possible revocation language.
4. Prepare accessible records: birth/marriage certificates, translations, property identifiers, insurance, banking, outstanding debts and executor contacts.
5. Obtain an assessment of UK IHT long-term residence and Bulgarian municipal inheritance/gift obligations before transferring property.
6. Agree how beneficiaries will manage a jointly inherited or undivided rural house, repair costs and sale decisions.

Official sources and review record

These primary sources are presented as starting points, not evidence that a specific taxpayer, inheritance, lender or shipment qualifies for a particular result. Rules, fees and bank products may change. The EU e-Justice Bulgarian country sheet notes that its English translation may lag the Bulgarian-language version; a local lawyer must check current legislation before advising on deadlines and inheritance rights.

• European e-Justice — Bulgaria succession ↗ — Rules for wills, reserved shares, heirship and succession procedure.
• EU — cross-border inheritance planning ↗ — EU Regulation 650/2012 and choice of national law.
• Bulgarian Finance Ministry — inheritance tax ↗ — Exempt relatives, municipal rates and declarations.
• Bulgarian Finance Ministry — gift tax ↗ — Gifts between spouses and lineal relatives.
• HMRC — long-term UK residence and IHT ↗ — Post-April 2025 overseas estate exposure.

Editorial source review: 17 October 2026. Publisher: PluginPip Ltd. Independent information, not regulated financial services, conveyancing, tax advice or legal representation. Seek advice on your facts before signing or moving substantial funds.