Bulgaria: Bulgaria implements CbCR

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Bulgaria: Bulgaria implements CbCR

intl-updates-small.jpg

Country-by-country reporting (CbCR) was implemented in Bulgarian legislation via the Act to Amend and Supplement the Tax and Social Security Procedure Code (TSSPC), which was published in issue 63 of the State Gazette on August 4 2017.

Through the introduction of CbCR, the tax authorities trying to implement stricter rules to combat tax avoidance and working on further harmonising local laws with OECD guidelines.

MNE groups will be obliged to submit the CbC report in Bulgaria in the following cases:

  • An ultimate parent entity of the MNE group is resident in Bulgaria and the total consolidated turnover of the group is in excess of BGN 100 million ($60 million); or

  • A constituent entity of the MNE group is resident in Bulgaria, whereas the ultimate parent company is not, and the consolidated turnover exceeds €750 million ($881 million).

The CbC report must include information for each entity of the MNE group, including the nature of the main business activities and some aggregated financial data.

In case the CbC report is completed by the ultimate parent company, it must be submitted to the tax authority electronically within 12 months of the last day of the group's reporting fiscal year. Otherwise, it must be submitted within 15 months of the abovementioned period. If the CbC report is submitted by the ultimate parent company, it should be prepared for the group's fiscal year commencing in 2016. If it concerns a constituent entity of the group, the report must be prepared for the group's fiscal year commencing in 2017.

To meet the above criteria, the tax authority must be notified:

  • By the ultimate parent Bulgarian resident entity of an MNE group, no later than the last day of the reporting fiscal year of the group; or

  • By a Bulgarian resident entity of the MNE group (excluding the above cases), describing which is the reporting entity submitting the CbC report and its jurisdiction of residence. The relative deadline is no later than the last day of the group's reporting fiscal year.

The notification for the first reporting period (2016) must be provided to the tax authority no later than December 31 2017.

The penalties for infringements include:

  • Failure to notify the tax authority will result in penalties ranging from BGN 50,000 to BGN 100,000 for the first violation, and from BGN 100,000 to BGN 200,000 for subsequent violations;

  • For not filing or delayed filing of the CbC report, penalties range between BGN 100,000 and BGN 200,000. When a repeated infringement occurs, the penalty may reach BGN 300,000; and

  • Incomplete or incorrect filing of the CbC report will lead to a penalty ranging between BGN 50,000 and BGN 150,000. For repeated infringements, the penalty may range between BGN 100,000 and BGN 200,000.

anastasiou.jpg

Maria Anastasiou

Maria Anastasiou (maria.anastasiou@eurofast.eu)

Eurofast

Tel: +30 210 8257720-22

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
The purchase of Marosa represents the second major tax tech consolidation this week, raising questions of a broader industry trend
Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Gift this article