Tax Alert – Changes to Tax and Social Security Procedure Code (CbCR) (EN)

Automatic Exchange of Information

 (Country-by-Country Reports)

 (in force as of 04.08.2017)

New rules on automatic exchange of information between the tax administrations by means of Country-by-Country Reports (CbCR) are introduced with the changes to the Tax And Social Security Procedure Code, in effect as of 4 August 2017.

Scope of the information subject to the CbCR

The automatic exchange of information will be performed by CbCR and will encompass information about the allocation of revenues, profits, assets and taxes of the entities within a multinational enterprise group.

The template forms for submission of the CbCR should be approved by the Executive Director of the National Revenue Agency (NRA) and should be published on the NRA’s official website until 31 October 2017.

Entities obliged to submit CbCR

The new rules on submission of CbCR are addressed to multinational enterprise groups (MNE Groups), which operate through subsidiaries or permanent establishments in different EU member states or third country jurisdictions.

Entities obliged to submit CbCR in Bulgaria  

The CbCR should be submitted to the NRA by the following companies:

  • Ultimate parent entity of a MNE Group

The ultimate parent entity part of a MNE Group should submit a CbCR to the NRA, provided that it is a Bulgarian tax resident and according to the accounting regulations should prepare a consolidated financial report and there is no other constituent entity of the MNE Group, which directly or indirectly controls that ultimate parent entity.

The ultimate parent entity submits a CbCR when the total consolidated turnover of the group exceeds BGN 100 000 000 (or app. EUR 51 000 000) for the fiscal year proceeding the reporting fiscal year.