If you have had the opportunity to follow us on this blog you will have seen how many times we have mentioned the great investment potential in Bulgaria, mainly linked to the fact that this nation, in addition to belonging to the European Union, with all the advantages that this entails from a in view of the freedom of movement of goods and people, it also has the great advantage of offering a universal flat tax of 10% which applies to both companies and the income of individuals without any income limit.

However, with respect to this first characterization, someone might object that not too far from Italy there are nations (think of the Principality of Monaco) in which even lower, even zero, tax regimes can be obtained. This is true but only in part because, if we take the Principality of Monaco as an example, it has an obvious difference compared to Bulgaria linked to the fact that it is not freely accessible to everyone. But there is more and it concerns proof of actual residence abroad which changes when talking about tax havens on the black list, such as the Principality of Monaco, and when talking about nations not on the black list such as Bulgaria.

What does it mean? The point to consider is very simple. Anyone who transfers their tax residence to Bulgaria does not have to prove their actual residence abroad. This means that in the event of a dispute by the Italian Revenue Agency, the latter must demonstrate that the citizen has not actually transferred his residence abroad. However, those who have transferred their residence to the Principality of Monaco, in the event of a dispute by the Revenue Agency, must also be responsible for demonstrating that this change of residence has actually occurred and for all intents and purposes (not just formally). You understand well that it is a significant difference, not only in practical terms, but also from a temporal and economic point of view, having to set up an organizational machine made up of professionals of various kinds (accountants and lawyers first and foremost) useful for demonstrating that they have actually moved your residence abroad if you have moved your tax residence to blacklisted countries.

On the contrary, it is both complicated and expensive for the Revenue Agency to have to prove that a taxpayer has fictitiously moved his tax residence to Bulgaria because this would require expensive investigative work. For this reason, to minimize complaints from the Italian tax authorities, we do not recommend moving your tax residence to blacklisted countries. Which ones are they? Based on the art. 1 (Fiscally privileged states for IRPEF purposes) de Decree of 04/05/1999 – Min. Finance, in force from 24/02/2014, modified by the Decree of 12/02/2014 Article 1 are: Alderney, Andorra (Principat d 'Andorra), Anguilla, Antigua and Barbuda (Antigua and Barbuda), Netherlands Antilles, Aruba, Bahamas, Bahrain, Barbados, Belize, Bermuda, Brunei, Costa Rica, Dominica, United Arab Emirates, Ecuador, Philippines, Gibraltar, Djibouti, Grenada, Guemsey, Isles of Man, Cayamn, Cook Island, Marshall Islands, Virgin Islands, Jersey, Lebanon, Liberia, Liechtenstein, Macau, Malaysia, Maldives, Mauritius, Nauru, Monserrat, Oman, Panama, French Polynesia, Monaco, Sark, Singapore, Saint Kitts, Saint Lucia, Saint Vincent and the Grenadines, Switzerland, Taiwan, Tomga. Turks and Caicos, Tuvalu, Uruguay, Vanatu, Samoa,