February 28 2022

Bulgaria Gazettes Reverse Hybrid Mismatch Rules

Source: IBFD Tax Research Platform News

Bulgaria has promulgated amendments to the Corporate Income Tax Act in the State Gazette as follows:

  • implementation of the rules for reverse hybrid mismatches provided in article 9a of theĀ Anti-Tax Avoidance Directive (2016/1164) (ATAD);
  • extension of the scope of application of the provisions for controlled foreign companies (CFCs) which will be applied to all Bulgarian taxable persons that are subject to corporate income tax in the country and have CFCs regardless of their form of taxation; and
  • clarification of the tax aspects of lease buy-back agreements, which are classified as operating leases under the International Accounting Standards.