Category: Bulgaria

EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to a Gibraltar companies from withholding tax

The Advocate General (AG) in an opinion issued 24 October (Case C-458/18) stated that a company incorporated in Gibraltar and subject to Gibraltar corporation tax cannot be considered to be a “company of a Member State” within the meaning of the parent-subsidiary directive (Directive 2011/96). ... - Continue reading

Pakistan, Bulgaria sign double taxation treaty

ISLAMABAD: Pakistan and Bulgaria on Tuesday signed an agreement to get rid of double taxation and cooperate in preventing tax evasion as a state delegation from the European Union member country concluded its two days visit. The Federal Board of Revenue (FBR) Director General and Deputy Minister of Economy Bulgaria… – Continue reading

Greece Raises BEPS Concerns With Bulgaria

The heads of the Greek and Bulgarian tax authorities have met to discuss ways in which bilateral cooperation can be boosted with a view to reducing levels of tax avoidance and evasion, particularly with respect to Greek companies shifting profits to Bulgaria. “The major issue of tax avoidance by Greek… – Continue reading

Bulgaria and Greece step up exchange of information to combat tax evasion

The head of the revenue agencies of Bulgaria and Greece have held talks on continuing and deepening co-operation on exchanging information and countering tax evasion, the National Revenue Agency in Sofia said on January 22. Bulgaria’s National Revenue Agency head, Galya Dimitrova, and her Greek counterpart Georgios Pitsilis discussed issues… – Continue reading

Bulgarian Presidency Outlines EU Tax Plans

The “fair and efficient” taxation of corporate profits and the fight against tax avoidance and evasion through enhanced administrative cooperation are among the priorities of the new Bulgarian presidency of the European Union, which commenced on January 1, 2018. The recently released program of the Bulgarian presidency states that it… – Continue reading

Bulgaria Requires CbC Reports By Year End

Bulgaria has said that multinationals covered by the country’s new transfer pricing country-by-country reporting regime should submit their first report by December 31, 2017. Through Order 3LIY-1410, Bulgaria’s National Revenue Agency has newly set out the rules concerning country-by-country documentation, including who the reporting obligations apply to and how to… – Continue reading

EU Takes Legal Action Against Portugal, Two Others on Tax Deals

The European Commission launched legal proceedings against Portugal, Bulgaria, and Cyprus for not adopting, in their national laws, European Union legislation requiring all EU countries to exchange tax rulings granted to multilateral companies. The legislation was adopted in the wake of the 2014 LuxLeaks scandal that revealed more than 100… – Continue reading

European Commission warns Bulgaria to get into line on tax rulings, anti-trust damages actions rules

Bulgaria is among European Union countries that the European Commission has sent a reasoned opinion because of its failure to communicate the transposition of new measures on the automatic exchange of tax rulings between EU tax authorities. The step was announced by the European Commission on July 13, among its… – Continue reading

Draft Bulgarian tax law reflects EU legislation on mandatory automatic exchange of tax information

At the end of March 2017, the Ministry of Finance called for public discussion on a draft bill (the “Bill”) amending the Bulgarian Tax and Social Insurance Procedural Code (the “Code”). The Bill seeks to improve administrative cooperation in the Bulgarian tax sector. The first set of amendments relates to… – Continue reading

Can Pay, Won’t Pay: Tax Evasion, Profit Shifting Rife in Central, Eastern Europe

The LuxLeaks and Panama Papers scandals aroused shock and outrage the world over. However, reaction from Central and Eastern European statesmen and citizens was decidedly more muted. A new report has suggested profit shifting and tax dodging by businesses in the region is endemic – perhaps accounting for the lack… – Continue reading

Investment under threat

It seems that our tax system is quite the topic of conversation. It has even been called “not European”, “not social” and “a harmful tax practice”. Indeed. The idea that there is some moral code that can be called ‘European’ is as absurd a notion as any I have ever… – Continue reading


The new 9 percent flat corporate profit tax – to be introduced 1st of January 2017 – will put Hungary in a very good position in the international race for investments as Hungary will offer even better conditions than Ireland and Cyprus, which are both often regarded as the European… – Continue reading

EU Mulls ‘Substance Test’ to Determine Zero-Rate Tax Havens

European Union member countries are considering a “substance test” to determine whether a country or jurisdiction with a zero corporate tax rate qualifies as a tax haven that doesn’t reflect “real economic activity.” After a host of EU member countries rejected in early November the use of a zero corporate… – Continue reading

Common Base Could End EU Patent Box, Transfer Pricing Disputes

Adoption of legislation for a common consolidated corporate tax base by 27 EU member states would resolve current patent box conflicts and end transfer pricing disputes that cost multinational companies hundreds of millions of dollars in double taxation, according to EU and industry officials. Speaking at a Nov. 15 conference… – Continue reading

Greece to Seek Help from Bulgaria, Cyprus to Find Suspected Tax Evaders

Greece intends to sign agreements with Bulgaria and Cyprus which will allow Athens to look into suspected tax evasion by Greek-owned companies registered in the two countries, Greek newspaper Kathimerini has reported. The closer inspection of Greek-owned companies registered in Bulgaria and Cyprus will aim to find out whether they… – Continue reading

Bulgaria adopts controversial amendments to the “Offshore Companies Act”

On 15 June 2016 the Bulgarian Parliament adopted long discussed amendments to the so called “Act on Economic and Financial Relations with Companies Registered in Jurisdictions with Preferential Tax Treatment, their Related Parties and Actual Owners” (the “Offshore Companies Act”, or the “Act”). The Act was adopted in 2014 and… – Continue reading

Bulgarian Parliament amends law on offshore companies

Bulgarian MPs passed at second reading on June 15 a bill easing ownership restrictions on offshore companies, amending a law that was adopted in December 2013. Under the amended law, which will go into effect on July 1, corporate entities registered in tax havens will be allowed to hold up… – Continue reading

Liberia: Africa’s unknown tax haven with much to lose

As world leaders consider what to do about the revelations emerging from the Panama Papers, Liberia’s government will be worrying about the fall-out that may cross the Atlantic Ocean from the affair. The European Union has announced it will be creating a new “tax haven blacklist”, to be released by… – Continue reading

Bulgaria definitively removes Gibraltar from ‘tax haven’ list

Bulgaria has definitively removed Gibraltar from its ‘tax haven’ list following intensive lobbying by Albert Isola, Minister for Financial Services, and the Gibraltar Finance Bulgaria team. This change has been reflected in the updated lists published on the European Commission website under ‘Tax good governance in the world as seen… – Continue reading

UK Tax Treaties With Croatia, Bulgaria In Force

The UK tax authority, HM Revenue and Customs (HMRC), has announced that new double tax avoidance treaties with Bulgaria and Croatia have entered into force. The 2015 UK-Bulgaria double tax agreement was signed on March 26, 2015, and replaces the former 1987 treaty. It generally limits the withholding tax rate… – Continue reading

UK – Bulgarian DTA entered into force

On January 8, 2016 the UK HM Revenue & Customs issued a media release announcing that on December 15, 2015 the Convention between the United Kingdom of Great Britain and Northern Ireland and the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with… – Continue reading

IP BOX: Italian and European Legal Framework

On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading

Blacklisted HK: The Italian Case

More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading

13 States Sign Up To OECD’s New Tax Info Exchange Standard

Thirteen jurisdictions signed the OECD Multilateral Competent Authority Agreement (MCAA) at a meeting on October 29-30, 2015, in Barbados. In joining the MCAA, the territories commit to automatically exchange tax information with other nations’ tax authorities under the OECD’s new tax information exchange standard, the Common Reporting Standard. A total… – Continue reading

Bulgarian Offshore Companies Act amendment seeks to ease restrictions

A newly introduced amendment to the Bulgarian Offshore Companies Act (the “Act”) will bring significant changes to investment opportunities for offshore companies. If the Bulgarian Parliament adopts the amendment within the next month, the amended Act is expected to enter into force in the beginning of 2016. The proposed amendments… – Continue reading


Global taxpayers can expect to pay more tax in the years ahead. Many governments worldwide continue to update their tax legislation and expand their tax systems to repay debt and pay for increased social welfare, even as the memory of the last global financial crisis lingers. These are the conclusions… – Continue reading

Bulgaria parliament to hold regular sitting

Sofia. Bulgarian parliament will hold a regular sitting on Friday. The Bulgarian lawmakers will continue the debates on the amendments to the Tax and Social Insurance Procedure Code. The amendments filed by the Council of Ministers introduce the regulations of the European directive concerning the realisation of automatic exchange of… – Continue reading

Blacklisted HK: The Latvian Case

The blacklisting of Hong Kong by the European Union is over for the moment with Spain explaining to the EU it didn’t have HK on its list. In the course of investigation, Harbour Times receives a quick response from the Latvian embassy in Beijing to clarify their stance on Hong… – Continue reading

Global Forum makes strides toward tax transparency

The timely and effective implementation of the automatic exchange of tax information was a key theme during the Oct. 29-30 meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes held in Bridgetown, Barbados. The meeting, which brought together delegates from the Global Forum’s 128 member… – Continue reading

OECD: Global Forum on tax transparency pushes forward international co-operation against tax evasion

Major implementation milestones are being met by members of the world’s leading forum on tax transparency as the international community continues to move ahead towards greater tax transparency. The imminent shift to the automatic exchange of information will send a strong warning to tax evaders. Significant strides towards a major… – Continue reading

Critical Guidelines for Taxpayers with Foreign Bank Accounts & Amnesty Program Information

Further strides towards greater tax transparency around the world have been made with 13 countries signing up to the international framework enabling the automatic exchange of information. The OECD’s 8th Global Forum on Transparency and Exchange of Information for Tax Purposes was held in Barbados on 29-30 October and brought… – Continue reading

Inniss: FATCA good for Barbados

Barbados’ reputation as a home of “serious” business and a “significant” player in international business is being enhanced with the adoption of a United States law which targets non-complaint US taxpayers with foreign accounts, Minister of International Business Donville Inniss has contended. In fact, Inniss suggested that the Foreign Accounts… – Continue reading

Transfer pricing makes big splash on global taxes

Multinationals have generated big-time revenues with its subsidiaries spread all over the world, which means huge profits and that’s taxable income. In recent years, a number of conglomerates – Amazon, Apple, Google and Starbucks – have engaged in so-called profit-shifting (profit allocation) via transfer pricing methods to pay minuscule taxes…. – Continue reading

Bulgaria joins automatic exchange of financial account information agreement

Sofia. Bulgaria joins the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information, the press office of the Bulgarian cabinet announced. The agreement was signed by 51 jurisdictions on October 29, 2014 in the frames of the Global Forum on Transparency and Exchange of Information for Tax Purposes… – Continue reading

EU blacklists Hong Kong as ‘non-cooperative tax jurisdiction’

Kenneth Leung (PC,F-Accountancy) explains what he – and the government – are doing to get Hong Kong off the EU’s undeserved blacklisting as a “non-cooperative tax jurisdiction”. Why has Hong Kong been placed on this list? There are ten European countries that have named Hong Kong as a tax haven…. – Continue reading

Bulgaria to exchange information with Guernsey on tax matters

Sofia. Bulgarian Council of Ministers approved at its regular Wednesday sitting an agreement on exchange of information on tax matters signed between the governments of Bulgaria and Guernsey. The cabinet proposes the National Assembly ratifies the document, the press service of the Government announced. The agreement sets conditions for the… – Continue reading

Worldwide: Governments Continue To Welcome Wealthy Foreigners

With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading