Bulgaria has implemented the OECD/G20 BEPS Action 13 Country-by-Country Reporting (CbCR) requirements as part of its commitment to international tax transparency. These obligations are embedded in national legislation and apply to multinational enterprise (MNE) groups meeting certain thresholds.

This guide outlines the essential aspects of Bulgaria’s CbCR regime, including applicability, compliance steps, deadlines, and penalties.

Regulatory Framework

• Authority: National Revenue Agency (NRA)
• Legislation:
  • Corporate Income Tax Act (CITA), Articles 92a–92d
  • Ordinance No. H-9/2017 on the content and format of CbC reports
• International Engagement:
  • Bulgaria is a signatory to the OECD Multilateral Competent Authority Agreement (MCAA)
  • Part of the Inclusive Framework on BEPS

CbCR Filing Requirements

• Who Must File:
  • Ultimate parent entities (UPEs) resident in Bulgaria of MNE groups with consolidated revenue of BGN 100 million or more in the previous fiscal year
  • Bulgarian constituent entities of foreign MNEs may be required to file under secondary filing rules if certain conditions are met
• CbCR Notification:
  • Bulgarian entities must notify the NRA of the reporting entity and jurisdiction of filing
  • Notification deadline: by the end of the financial year
• CbCR Submission:
  • Deadline: within 12 months of the end of the fiscal year
  • Submission is made electronically in OECD-standard XML format through the NRA portal

Penalties for Non-Compliance

• Failure to submit or provide correct data:
  • Fines ranging from BGN 100 to BGN 20,000 for individuals and legal persons
  • Higher penalties for repeated offenses

Important Considerations

• Bulgaria participates in automatic exchange of CbC reports under international agreements
  • Alignment with the OECD’s three-tiered approach: Master File, Local File, and CbCR
• Consistency across all documentation is critical to reduce audit risk

Useful Resources

• National Revenue Agency (NRA): https://nra.bg
• Ordinance H-9/2017 (Bulgarian): https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=117917
• OECD CbCR Overview: https://www.oecd.org/tax/beps/country-by-country-reporting.htm