November 6 2018

Obligatory transfer pricing documentation proposed

Source: IBFD Tax Research Platform News

The Ministry of Finance initiated a public consultation on a bill to amend the Tax and Social Security Procedures Code.

The bill proposes the implementation of obligatory transfer pricing documentation for certain entities and certain transactions depending on balance sheet data of companies and materiality of transactions.

Entities with a balance sheet value of assets exceeding BGN 8 million (EUR 4 million) and net sales revenue exceeding BGN 16 million (EUR 8 million) will be required to prepare transfer pricing documentation on transactions with goods (exceeding BGN 400,000), services (exceeding BGN 200,000), intangible assets (exceeding BGN 200,000) and financial assets (exceeding BGN 200,000). Transfer pricing documentation will also need to cover loan transactions exceeding BGN 2 million or interest payments exceeding BGN 100,000.

The public consultation will end on 5 December 2018, after which the bill, as amended, is scheduled to be delivered to the parliament for voting.