January 3 2020

Interim measures for non-reciprocal status for automatic exchange of CbC reports – announced

Source: IBFD Tax Research Platform News

In a letter circulated to taxpayers in mid-December 2019, the Bulgarian National Revenue Agency (NRA) announced interim measures with respect to the temporary status of Bulgaria as a "non-reciprocal jurisdiction" under the Multilateral Competent Authority Agreement on the automatic exchange of Country-by-Country reports (CbC MCAA) i.e. Bulgaria has committed to send CbC reports but will not receive CbC reports from its exchange partners.

Bulgaria's non-reciprocal status will affect Bulgarian constituent entities filing CbC reports who are part of non-EU multinational groups (i.e. groups with consolidated revenue above EU 750 million).

The NRA announced that, pending the restoration of the automatic exchange of CbC reports, it will request such CbC reports from its partner jurisdictions by means of the bilateral agreement for administrative cooperation in tax matters.

For 2018, Bulgarian constituent entities of foreign multinational groups filing CbC reports will not be required make a separate local filing of the group's CbC report or to change the jurisdiction of the reporting entity to a jurisdiction exchanging CbC reports with Bulgaria.