Bulgaria introduced its law for Transfer Pricing documentation requirements and implementation of EU tax dispute directive which incorporated under the Tax and Social Security Procedure Code. The main amendments include: introduction of mandatory transfer pricing documentation requirements and implementation of the EU Tax Dispute Resolution Directive.
The following persons will be obliged to prepare transfer pricing documentation:
An exemption from the obligation to prepare transfer pricing documentation applies if one or more of the following conditions are met for:
The local file must be prepared by 31 March after the end of the relevant tax year. The persons obliged to prepare a master file must do so not later than 1 year after the deadline for preparing the local file for the relevant year. Since the first tax year for which the transfer pricing documentation must be prepared is 2020, the deadline for this first period therefore is 31 March 2021 for both the local and the master files.
The Law provides for the implementation of EU directive on dispute resolution which 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.
Source: Bulgarian Parliament
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