On 5 June 2019, the Bulgarian parliament reportedly voted to approve amendments in the first reading of the draft tax legislation for the introduction of new transfer pricing documentation requirements, including Local and Master file requirements (previous coverage).
One of the main amendments is in relation to the requirements to prepare documentation in respect of loan transactions. This includes that documentation must be prepared if the total amount of loans received or granted exceeds BGN 1 million or the total amount of accrued interest and other related receipts and expenses exceeds BGN 50,000. This is a reduction in the thresholds originally proposed, which were BGN 2 million and BGN 100,000, respectively.
Another important amendment is that the documentation preparation threshold for other categories of transactions will generally be applied on a per-transaction basis instead of aggregated amounts, although aggregation may still apply certain case. The effective date of the documentation requirement is also changed so that the requirements would apply from 2020, instead of 2019 as originally proposed.
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