A few years after the Organisation for Economic Development and Cooperation (“OECD”) published on 19th July 2013 its Action Plan on Base Erosion and Profit Shifting (“BEPS Action Plan”) as a major initiative to modify existing international tax rules and consisting of 15 actions to provide the governments instruments to address tax avoidance, one of its actions is now implemented in Bulgaria as another effort to increase tax transparency. It is Action 13 of the BEPS Action Plan, which prescribes that governments should be provided with certain information for multinational enterprise groups (“MNE Groups”). A piece of such information to be provided by MNE Groups is the country-by-country report. In response to Action 13 of the BEPS Action Plan the Council of the European Union adopted Council Directive (EU) 2016/881 of 25th May 2016 (“Directive”), which should have been implemented by Member States, including Bulgaria, by 4th June 2017 and applied from 5th June 2017. Pacing up, Bulgaria has now taken the necessary steps to introduce and comply with the reporting regime required by the Directive. The country-by-country reporting (“CbCR”) legislation introduced by the Directive is implemented in Bulgaria through significant changes to the Tax and Social Security Procedure Code (“TSSPC”), as recently passed by the Parliament and promulgated on 4th August 2017.
When a Bulgarian company is obliged to file country-by-country report? What are the deadlines and sanctions? Check our lawyers’ recap in the Publications section on our website.