All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

Bulgaria: Bulgaria implements CbCR


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.


Maria Anastasiou

Maria Anastasiou (


Tel: +30 210 8257720-22


More from across our site

But experts cast doubt on HMRC's data and believe COVID-19 would have increased the revenue shortfall.
EY’s plan to separate its auditing and consulting businesses might lessen scrutiny from global regulators, but the brand identity could suffer, say sources.
Multinationals are asking world leaders to put a scale on carbon pricing to tackle climate change at the 48th G7 summit in Germany, from June 26 to 28.
The state secretary told the French press that the country continues to oppose pillar two’s global minimum tax rate following an Ecofin meeting last week.
This week the Biden administration has run into opposition over a proposal for a federal gas tax holiday, while the European Parliament has approved a plan for an EU carbon border mechanism.
12th annual awards announce winners
Businesses need to improve on data management to ensure tax departments become much more integrated, according to Microsoft’s chief digital officer at a KPMG event.
Businesses must ensure any alternative benchmark rate is included in their TP studies and approved by tax authorities, as Libor for the US ends in exactly a year.
Tax directors warn that a lack of adequate planning for VAT rule changes could leave businesses exposed to regulatory errors and costly fines.
Tax professionals have urged suppliers of goods from Great Britain to Northern Ireland to pause any plans to restructure their supply chains following the NI Protocol Bill.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree