January 2020 / Bulgaria

January 3 2020

Amendments to VAT Act regarding requirements for intra-Community supplies – additional information

On 31 December 2019, amendments to the VAT Act regarding the documentation requirements for intra-Community supplies were promulgated in the State Gazette. The amendments have been adopted and will enter into force 2 weeks after the proposal was introduced into parliament In essence, the changes come in response to amendments to the VAT Act of 6 December 2019, which introduced new mandatory documentation requirements under article 45a of Implementing Regulation (EU) 282/2011, necessary to apply a 0% VAT rate to an intra-Community supply. Article 45a of Implementing Regulation (EU) 282/2011 provided enhanced requirements regarding the documents, in which VAT-registered suppliers had to collect at least 2 separate non-contradicting documents from a pre-approved list of options in order to prove the dispatch of goods from Bulgaria to other EU-Member States. Previously, it was sufficient for suppliers to prove the dispatch based on a single document for transport i.e. either a valid transport document or a written confirmation by the recipient.
January 3 2020

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

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.