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

  • Surrogate parent entity of a MNE Group

If the ultimate parent entity of a MNE Group is not a Bulgarian tax resident, the CbCR is submitted in Bulgaria by a Bulgarian tax resident surrogate entity/ a constituent  provided that the total consolidated revenue of the Group exceeds BGN 1 466 872 500 (or app. EUR 750 000 000).

Bulgarian surrogate parent entity of an MNE Group, files the CbCR in Bulgaria, when:

  1. The ultimate parent entity is not obliged to submit a CbCR in the jurisdiction as per its tax residency, or
  2. The jurisdiction in which the ultimate parent entity is a tax resident has an international agreement in force and Bulgaria is also party to that agreement, but for the period in which the CbCR is due for the reporting fiscal year there is no effective special international agreement.
  3. The jurisdiction as per tax residency of the ultimate parent entity of the Group systematically does not comply with the rules on exchange of information.


  • Constituent entity of a MNE Group

If the MNE Group does not submit the CbCR by a surrogate entity in Bulgaria, then the CbCR is filed by a constituent entity which is tax resident in Bulgaria.

If a MNE Group has several constituent entities – tax resident in Bulgaria/and or in other EU member state and any of the above described conditions is in place, the MNE Group may appoint one of the constituent entities to submit the CbCR.

If the constituent entity which is appointed to file the CbCR, is a tax resident of Bulgaria, that entity should notify the Executive Director of the NRA that by submission of the CbCR the reporting obligation of any other constituent entities of the MNE Group will be deemed fulfilled.

CbCR submission deadlines

The CbCR will be submitted electronically each year to the Executive Director of the NRA, within a 12-month term as of the end of the fiscal reporting year of the MNE Group.

The primary CbCR, which is filed by the ultimate parent entity of a MNE Group or by the surrogate parent entity of a MNE, which refers to the fiscal year starting on 1 January 2016, should be filed to the NAR no later than 31 December 2017.

For primary reporting by a constituent entity – CbCR is first to be prepared and filed for the fiscal years starting on 1 January 2017. The filing deadline is 31 December 2018.