Yesterday, November 1, 2017 the National Revenue Agency (“NRA”) published its October 31st 2017 Order on filing of country-by-country reports and reporting-entity notifications (“the Order”). Following a requirement under the rules on country-by-country reporting, effective in Bulgaria as of August 4, 2017, NRA issued the Order to clarify the procedure and format for filing of country-by-country reports and reporting-entity notifications.
In terms of procedure, entities obliged to file country-by-country reports and related notifications should do so electronically using qualified electronic signature. The “Electronic services with E-signature” section on the NRA Internet site will procure the filings through its newly introduced sub-section “Provision of information for the purposes of automatic exchange in the field of direct taxation”. The new sub-section will introduce two new electronic services: “Provision of country-by-country reports under Art.143ф of the Tax and Social Security Procedure Code by multinational enterprise group” and “Notification under Art.143ш of the Tax and Social Security Procedure Code in relation to filing of country-by-country reports by multinational enterprise groups”.
The two new electronic services should become available on 1 December 2017 the latest.
Entities who made filing will receive incoming number and confirmation for acceptance of filing at the e-mail address specified in their application for use of NRA electronic services.
In terms of format, the two schedules of the Order specify the form and content of the country-by-country reports and reporting-entity notifications.
In view of the approaching deadline for filing of reporting-entity notifications (31 December 2017 for 2016 reporting year), Bulgarian entities part of multinational enterprise groups should take steps towards clarifying their status for country-by-country reporting purposes within the group and obtain the information necessary to comply with their notification (and if applicable filing) obligations.