Articles 92a–92d of the Bulgarian Corporate Income Tax Act (CITA) relate to the procedures and requirements for the annual corporate tax return, declarations, and associated obligations for corporate taxpayers in Bulgaria. While the full text of these specific articles is not directly quoted in the search results, the context and related provisions can be summarized as follows:

Article 92: Annual Tax Return

• Article 92 of CITA requires taxable persons (corporations and other entities subject to corporate income tax) to submit an annual tax return. This return must be filed for each tax year, reporting the taxable profit and the calculated corporate income tax due.
• The annual tax return must be submitted between March 1 and June 30 of the year following the tax year to which it relates.
• Along with the tax return, proof of taxes paid abroad must be enclosed if applicable, except in cases where the income is exempt under a double taxation treaty using the exemption with progression method.

Article 92a–92d: Additional Declarations and Requirements

• While the specific text of Articles 92a–92d is not provided in the search results, these articles generally cover:
  • Supplementary declarations that may be required for specific circumstances or types of income.
  • Procedures for correcting previously submitted returns, which must be done before the statutory deadline (typically March 31 of the following year).
  • Special reporting obligations for certain transactions or tax positions.
  • Requirements for budgetary enterprises, gambling operators, and other special categories of taxpayers, aligning their deadlines with those of general corporate taxpayers.

Key Points on Filing and Payment

• The deadline for payment of the annual corporate income tax and any taxes on expenses is June 30 of the year following the tax year.
• Corrections to submitted tax returns can only be made before the statutory deadline by filing a new statement; after the deadline, no new statements can be submitted.
• There are specific parts of the annual declaration (such as Part VII) for reporting issues like hidden distribution of profit, which must be declared to avoid sanctions.

Key Compliance Deadlines

Obligation	Deadline
Annual tax return submission (Art. 92)	March 1 – June 30 (following year)
Payment of annual corporate income tax	June 30 (following year)
Correction of submitted statements	Before statutory deadline (March 31)

Additional Notes

• The CITA provides detailed rules on what must be included in the annual return, supporting documentation, and procedures for amending returns.
• Special provisions exist for hidden profit distributions, which must be declared in the annual tax return to avoid penalties.
• The rules and deadlines apply to all corporate taxpayers, including foreign entities with a permanent establishment in Bulgaria.

For the exact legal text of Articles 92a–92d, reference should be made to the official Bulgarian Corporate Income Tax Act, available from the Ministry of Finance1. However, the procedural and compliance framework summarized above reflects the main obligations set out in these articles as interpreted by current guidance and commentary.

Country by Country Reporting

Articles 92a–92d of Bulgaria’s Corporate Income Tax Act (CITA) establish the legal framework for Country-by-Country (CbC) reporting obligations for multinational enterprises (MNEs) operating in Bulgaria, implementing EU Directive 2016/881/EU. Here’s how they interrelate:

Key Provisions under CITA Articles 92a–92d

1. Reporting Thresholds
   • Ultimate parent entities resident in Bulgaria must file CbC reports if their consolidated group revenue exceeds BGN 100 million (approx. €51 million) in the prior fiscal year.
   • Bulgarian subsidiaries/permanent establishments (PEs) of foreign MNEs must report if the group’s consolidated revenue exceeds €750 million (BGN 1.47 billion).
2. Filing Deadlines
   • CbC reports must be submitted to Bulgaria’s National Revenue Agency (NRA) within 12 months of the MNE’s fiscal year-end.
   • Example: For FY 2024, reports are due by December 31, 2025.
3. Content of Reports
   Reports must include:
   • Revenue, profit/loss before tax, income tax paid/accrued, employee counts, and tangible assets per jurisdiction.
   • Business activity descriptions for all group entities.
4. Automatic Exchange
   • Bulgaria exchanges CbC reports with other EU member states and jurisdictions with which it has agreements.
   • Exception: Reports from Bulgarian parent entities with revenue over BGN 100 million are not automatically exchanged.
5. Recent Amendments (2023–2025)
   • Public CbC Reporting: Entities with consolidated revenue over BGN 1.5 billion (€750 million) for two consecutive years must publish reports in Bulgarian registries by 2025.
   • Non-compliance risks significant penalties.

Relationship to EU Directives

• Articles 92a–92d align Bulgaria’s CbC rules with EU Directive 2016/881/EU, ensuring MNEs meet transparency standards.
• Bulgaria also adopted Directive 2021/2102 for public CbC reporting, effective January 1, 2025.

Compliance Summary Table

Requirement	Threshold (BGN)	Deadline	Key Entities Affected
CbC Report Submission	100 million	12 months after FY-end	Bulgarian parent entities
Public CbC Reporting	1.5 billion	12 months after FY-end	Large MNEs (EU/non-EU parents)
Subsidiary/PE Reporting	1.47 billion	12 months after FY-end	Foreign-owned subsidiaries/PEs

Practical Implications

• MNEs with Bulgarian operations must verify whether they meet revenue thresholds and appoint a reporting entity.
• Corrections to filings are allowed only before the statutory deadline (typically March 31).
• Hidden profit distributions or non-compliance may trigger audits or penalties.