Bulgaria: Bulgaria implements CbCR

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Bulgaria: Bulgaria implements CbCR

intl-updates-small.jpg

Country-by-country reporting (CbCR) was implemented in Bulgarian legislation via the Act to Amend and Supplement the Tax and Social Security Procedure Code (TSSPC), which was published in issue 63 of the State Gazette on August 4 2017.

Through the introduction of CbCR, the tax authorities trying to implement stricter rules to combat tax avoidance and working on further harmonising local laws with OECD guidelines.

MNE groups will be obliged to submit the CbC report in Bulgaria in the following cases:

  • An ultimate parent entity of the MNE group is resident in Bulgaria and the total consolidated turnover of the group is in excess of BGN 100 million ($60 million); or

  • A constituent entity of the MNE group is resident in Bulgaria, whereas the ultimate parent company is not, and the consolidated turnover exceeds €750 million ($881 million).

The CbC report must include information for each entity of the MNE group, including the nature of the main business activities and some aggregated financial data.

In case the CbC report is completed by the ultimate parent company, it must be submitted to the tax authority electronically within 12 months of the last day of the group's reporting fiscal year. Otherwise, it must be submitted within 15 months of the abovementioned period. If the CbC report is submitted by the ultimate parent company, it should be prepared for the group's fiscal year commencing in 2016. If it concerns a constituent entity of the group, the report must be prepared for the group's fiscal year commencing in 2017.

To meet the above criteria, the tax authority must be notified:

  • By the ultimate parent Bulgarian resident entity of an MNE group, no later than the last day of the reporting fiscal year of the group; or

  • By a Bulgarian resident entity of the MNE group (excluding the above cases), describing which is the reporting entity submitting the CbC report and its jurisdiction of residence. The relative deadline is no later than the last day of the group's reporting fiscal year.

The notification for the first reporting period (2016) must be provided to the tax authority no later than December 31 2017.

The penalties for infringements include:

  • Failure to notify the tax authority will result in penalties ranging from BGN 50,000 to BGN 100,000 for the first violation, and from BGN 100,000 to BGN 200,000 for subsequent violations;

  • For not filing or delayed filing of the CbC report, penalties range between BGN 100,000 and BGN 200,000. When a repeated infringement occurs, the penalty may reach BGN 300,000; and

  • Incomplete or incorrect filing of the CbC report will lead to a penalty ranging between BGN 50,000 and BGN 150,000. For repeated infringements, the penalty may range between BGN 100,000 and BGN 200,000.

anastasiou.jpg

Maria Anastasiou

Maria Anastasiou (maria.anastasiou@eurofast.eu)

Eurofast

Tel: +30 210 8257720-22

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

It follows a court case concerning a Freedom of Information request lodged by the founder of a software company
After years of deafening silence, the UK tax authority is taking overdue action against corporates that fail to prevent the facilitation of tax evasion
The US president has raised India’s tariff rate to 50% because of its importation of Russian oil; in other news, firms made key international tax partner hires
Tax auditors themselves had not been aware of the new TP ‘transaction matrix’ requirements, ITR hears as five German partners share their client experiences
Its features include a built-in AI assistant as well as expert insights and commentary from Deloitte specialists
AI is rapidly finding its way into tax advisory services. But how can AI be deployed responsibly, reliably, and in compliance with legal standards?
Specified taxpayers will have to apply a 19% VAT rate on services offered by third parties through their platforms; in other news, Donald Trump imposed 30% South African tariffs
A ‘quiet revolution’ in HMRC’s compliance strategy has caused Adam Craggs to rethink how to advise clients, he tells ITR
If the Reform leader becomes UK prime minister then he may follow the direction of the US in at least one significant way
Trump declared a new national emergency in issuing the order; in other news, Grant Thornton Germany is up for sale and the subject of interest from both its UK and US counterparts
Gift this article