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Tax News: The procedure and form for submission of Country-by-Country reports have been set

Tax News

KPMG Tax News presents legislative changes and trends in the area of taxation.


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The fourth issue of Tax News for 2017 provides information about the order of the National Revenue Agency with respect to the automatic exchange of Country-by-Country reports.

CbC reporting

The submission of Country-by-Country reports (CbC reports) – part of the global initiatives against tax avoidance and profit shifting (the BEPS Action Plan) – now has its practical dimensions in Bulgaria. The procedure and the form for submission of the CbC reports and the notification with respect to the entity that will submit the CbC report were approved yesterday, 31 October 2017, by virtue of NRA Order ЗЦУ-1410.

The order also sets out the data to be filed in the report and the notification by the taxpayers.

The CbC report and the notification shall be submitted electronically through the respective electronic services that will be available on the NRA website no later than 1 December 2017.

The first CbC report shall be prepared for the fiscal year of the Group starting in (i) 2016 if the CbC report is submitted by the ultimate or surrogate parent company or (ii) 2017 if the CbC report is submitted by a constituent entity of the Group.

Thus, if the CbC report is submitted by the ultimate or surrogate parent company that is tax resident in Bulgaria, the first CbC report for the fiscal year starting on 1 January 2016 and ending on 31 December 2016 shall be submitted until 31 December 2017.

The deadline for submission of the notification for the reporting fiscal year starting in 2016 is 31 December 2017.

Tax Forum of KPMG in Bulgaria

The new obligations of the Bulgarian taxpayers in relation to CbC reporting, as well as the practical aspects related to these obligations will be on the agenda of the Tax Forum of KPMG in Bulgaria with leading experts from the NRA on 2 November 2017.

Further information about the event is available here.

© 2018 KPMG Bulgaria OOD, a Bulgarian limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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