Entering the Greek market can create significant opportunities for Bulgarian companies — but successful expansion requires careful planning around company structure, taxation, VAT, employment, accounting and ongoing compliance.
For a Bulgarian company considering Greece as its next market, the key question is not simply “How do we establish a business in Greece?” but rather:
“What is the most appropriate structure for our activity, and how can we enter the Greek market while remaining tax-efficient and fully compliant?”
At ATHENS ACCOUNTING – ΛΟΓΙΣΤΙΚΗ ΑΘΗΝΩΝ, we support companies and entrepreneurs looking to develop business activity in Greece, providing accounting, tax and business advisory support throughout the process.
1. Why expand from Bulgaria to Greece?
Bulgaria and Greece are both EU Member States, which provides an important framework for cross-border commercial activity.
A Bulgarian company may enter the Greek market in several different ways:
- selling products to Greek businesses;
- providing services to Greek clients;
- operating through a Greek branch;
- establishing a Greek subsidiary;
- creating a new Greek company;
- employing personnel in Greece;
- establishing a physical office, shop, warehouse or other fixed presence;
- developing an e-commerce operation targeting Greek consumers.
The appropriate structure depends heavily on the company’s business model, expected turnover, personnel requirements, physical presence and relationship between the Bulgarian and Greek operations.
There is therefore no single solution that is appropriate for every Bulgarian business.
2. Bulgarian company or Greek company?
One of the first strategic decisions is whether the Bulgarian company should operate directly in Greece or establish a separate Greek entity.
Option A: Operate from Bulgaria
For certain activities, a Bulgarian company can provide services or sell products into Greece without immediately establishing a Greek company.
EU rules allow businesses established in one Member State to provide services in another Member State, although sector-specific requirements and administrative obligations may apply.
This model can be useful when a company wants to:
- test the Greek market;
- work with a limited number of Greek customers;
- provide services remotely;
- avoid establishing a permanent physical presence initially.
However, the VAT, permanent-establishment, employment and local regulatory implications should be examined before commencing activity.
3. Establishing a Greek subsidiary
For businesses intending to develop a substantial and long-term presence in Greece, establishing a Greek company may be appropriate.
A Greek subsidiary operates as a separate legal entity and can:
- enter into contracts with Greek customers;
- employ staff;
- lease premises;
- open business banking facilities;
- issue Greek invoices;
- maintain Greek accounting records;
- participate in Greek financing or investment programmes where eligible.
For many businesses, the ΙΚΕ (Private Company) is one of the corporate structures that should be considered when evaluating establishment in Greece.
The choice of legal form, however, should be made after examining the company’s ownership structure, investment plans, liability considerations and tax position.
4. Branch vs subsidiary
Another important question is whether to establish a branch of the Bulgarian company or a separate Greek company.
A branch remains connected to the Bulgarian parent company, while a subsidiary is a separate Greek legal entity.
The decision can affect:
- corporate governance;
- accounting;
- taxation;
- liability;
- transfer of funds;
- contracts;
- financing;
- reporting requirements;
- the relationship between the Bulgarian and Greek businesses.
There is no universal answer. The structure should reflect the actual commercial model rather than being selected solely on the basis of incorporation cost.
5. Understanding Greek taxation
Tax planning is one of the most important parts of a Bulgaria-to-Greece expansion.
According to the Greek Independent Authority for Public Revenue (AADE), the standard corporate income tax rate for companies in Greece is 22%. The standard VAT rate is 24%, with reduced rates applying to specific categories of goods and services.
However, the headline tax rate is only one part of the calculation.
A company should also examine:
- deductible business expenses;
- VAT treatment;
- withholding taxes;
- payroll taxation;
- social-security contributions;
- dividend taxation;
- related-party transactions;
- transfer pricing;
- permanent-establishment issues;
- the applicable Greece–Bulgaria tax framework.
This is particularly important when the Bulgarian and Greek businesses are related companies.
6. VAT when doing business between Bulgaria and Greece
VAT is one of the areas where cross-border businesses need particularly careful advice.
For example, when a VAT-registered business in Bulgaria sells goods to a VAT-registered business in Greece, the transaction may qualify as an intra-EU transaction subject to the applicable EU VAT rules.
Similarly, B2B services supplied between businesses in different EU Member States are generally subject to the place-of-supply rules, with the reverse-charge mechanism applying in many cases. There are, however, important exceptions depending on the type of service.
This means that a Bulgarian company should not simply assume that “EU transaction = no Greek VAT.”
The correct VAT treatment depends on factors such as:
- whether the customer is a business or private individual;
- where the customer is established;
- the nature of the goods or services;
- where the goods are transported;
- whether there is a fixed establishment;
- whether special VAT rules apply.
A Bulgarian business carrying out transactions taxable in Greece can, under certain circumstances, obtain a Greek tax identification number for VAT purposes without appointing a Greek tax representative. The Greek government’s EUGO service describes the relevant procedure for businesses established in another EU Member State.
7. Selling to Greek consumers
The situation can be different when a Bulgarian company sells directly to Greek consumers (B2C).
This is particularly relevant for:
- e-commerce;
- online subscriptions;
- digital services;
- distance sales;
- marketplaces;
- tourism-related businesses.
EU VAT rules contain specific provisions for cross-border B2C transactions, including the One Stop Shop (OSS) system for qualifying transactions.
Before launching an online business targeting Greece, the company should determine:
Where is VAT due?
Which VAT rate applies?
Does the company need Greek VAT registration?
Can OSS be used?
Are there product-specific rules?
These questions should be answered before the first significant volume of Greek sales.
8. Hiring employees in Greece
If the Bulgarian company intends to employ people who work in Greece, the analysis becomes considerably more complex.
The company should examine:
- employment contracts;
- payroll;
- Greek social-security obligations;
- employee taxation;
- working-time requirements;
- holiday and leave rules;
- employment reporting;
- applicable collective arrangements;
- employer registrations;
- potential permanent-establishment implications.
A company should not assume that an employee can simply be placed in Greece under the Bulgarian payroll indefinitely without examining the Greek obligations.
For businesses planning a Greek team, proper payroll and employment compliance should therefore be incorporated into the expansion plan from the beginning.
9. Accounting and financial reporting in Greece
Once a business establishes taxable or operational activity in Greece, proper accounting infrastructure becomes essential.
A Greek operation may require ongoing support with:
- bookkeeping;
- VAT returns;
- income tax obligations;
- payroll;
- invoices and expense documentation;
- financial statements;
- myDATA obligations;
- tax compliance;
- management reporting;
- communication with Greek authorities.
For a Bulgarian parent company, an additional challenge is ensuring that information flows efficiently between the Bulgarian and Greek accounting systems.
A well-designed reporting process should allow management to see both:
Bulgaria operations → Greece operations → consolidated business picture
without creating unnecessary duplication.
10. Opening a physical presence in Greece
If the company plans to establish:
- an office;
- retail premises;
- warehouse;
- production facility;
- restaurant;
- hotel;
- showroom;
- logistics operation;
additional regulatory and tax considerations may arise.
Depending on the activity, the business may need to examine:
- lease agreements;
- business premises;
- municipal requirements;
- licences or notifications;
- fire-safety requirements;
- employment requirements;
- sector-specific regulations;
- VAT registration;
- accounting setup.
For regulated activities, professional legal and tax advice should be obtained before signing long-term commitments.
11. Banking and financial management
A Greek operation will often require a practical banking and payments structure.
Businesses should consider:
- whether a Greek bank account is required;
- payment collection from Greek customers;
- supplier payments;
- payroll payments;
- intercompany transfers;
- currency considerations;
- documentation supporting transfers between related companies.
Where money moves between the Bulgarian parent and Greek subsidiary, the purpose and accounting treatment of those transactions should be properly documented.
12. Transfer pricing between Bulgaria and Greece
This becomes particularly important when the Bulgarian and Greek entities are related.
Examples include:
Bulgarian parent → Greek subsidiary
- management services;
- IT services;
- marketing;
- financing;
- intellectual property;
- procurement;
- administrative support.
The pricing of these transactions needs to be considered under the applicable transfer-pricing framework.
The objective is not simply to decide internally what amount should be charged.
The transactions should be appropriately documented and supported by the applicable rules.
13. A practical expansion roadmap
For a Bulgarian company planning to enter Greece, we recommend approaching the project in stages.
Step 1 — Business model analysis
Identify:
- what the company will sell;
- who the customers are;
- where the services are performed;
- where goods are stored;
- whether employees will be located in Greece;
- whether premises are required.
Step 2 — Tax & VAT analysis
Determine:
- corporate tax implications;
- VAT treatment;
- Greek VAT registration requirements;
- withholding taxes;
- cross-border transaction treatment;
- permanent-establishment considerations.
Step 3 — Choose the structure
Evaluate:
Bulgarian company operating cross-border
vs.
Greek branch
vs.
Greek subsidiary/company
Step 4 — Establish the Greek operation
Depending on the selected structure:
- incorporation/registration;
- tax registration;
- accounting setup;
- banking;
- premises;
- contracts;
- payroll.
Step 5 — Build the compliance system
Before operations begin, establish processes for:
- accounting;
- invoicing;
- VAT;
- payroll;
- tax deadlines;
- myDATA;
- financial reporting.
Step 6 — Ongoing business support
Once the company is operational, accounting should become part of the management system rather than simply a year-end compliance function.
14. Common mistakes when entering Greece
Some of the most common issues businesses should avoid include:
❌ Choosing the company structure based only on incorporation cost
The cheapest setup initially may not necessarily be the most appropriate for the long-term business model.
❌ Treating Greece and Bulgaria as having identical tax systems
Both countries operate within the EU framework, but national tax and compliance rules differ.
❌ Assuming all intra-EU transactions are VAT-free
VAT treatment depends on the precise transaction and the applicable rules.
❌ Hiring employees before understanding Greek payroll obligations
Employment in Greece can create significant ongoing compliance responsibilities.
❌ Ignoring related-party transactions
Payments between a Bulgarian parent and Greek subsidiary should be properly structured and documented.
❌ Waiting until after the business starts to organise accounting
The accounting infrastructure should ideally be designed before the first Greek transaction.
15. Bulgaria to Greece: Your business partner in Greece
Expanding from Bulgaria to Greece is more than a company-formation exercise.
It requires coordination between:
Corporate Structure
↓
Tax Planning
↓
VAT
↓
Accounting
↓
Payroll
↓
Compliance
↓
Business Development
At ATHENS ACCOUNTING – ΛΟΓΙΣΤΙΚΗ ΑΘΗΝΩΝ, we can support Bulgarian companies that want to establish or develop business activity in Greece, providing an integrated point of contact for accounting, taxation and business support.
Our Bulgaria to Greece Business Desk is designed to help entrepreneurs and companies navigate the practical requirements of entering the Greek market.
From Bulgaria to Greece — with the right preparation.
ATHENS ACCOUNTING – ΛΟΓΙΣΤΙΚΗ ΑΘΗΝΩΝ
Bulgaria to Greece Business Desk
Accounting • Tax • Payroll • Business Advisory
Disclaimer: This article is intended for general business information and does not constitute individualized tax, legal or accounting advice. Cross-border tax and VAT treatment depends on the specific facts and circumstances of each business and should be reviewed before implementation.
