On 13 August 2019, Bulgaria published the Law on Amendment and Supplementation of the Tax and Social Insurance Procedure Code. One of the main aspects of the Law is the introduction of new Local and Master file documentation requirements that are in line with BEPS Action 13. Key points include:
The Law also amends the Country-by-Country (CbC) reporting thresholds. Under the original requirements, the threshold for Bulgarian ultimate parents to submit a CbC report was set at just BGN 100 million (~EUR 51 million), while the threshold for groups with a non-resident ultimate parent was set at BGN 1,466,872,500 (near equivalent of EUR 750 million). The Law repeals the threshold provision for resident ultimate parents and amends the wording of the non-resident threshold provision so that it applies for all MNE groups. It also includes a transitional provision, which provides that group's meeting the BGN 100 million threshold for resident ultimate parents prior to the Law's entry into force are not required to submit a CbC report for 2019.
Lastly, the Law provides for the implementation of Council Directive (EU) 2017/1852 of 10 October 2017. This includes measures to ensure effective resolution of disputes concerning the interpretation and application of bilateral tax treaties and the Union Arbitration Convention, and in particular, disputes leading to double taxation. The measures apply to disputes filed from 1 July 2019 in relation to tax years beginning on or after 1 January 2018.
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