Bulgaria: New deadline for transfer pricing documentation

Bulgaria: New deadline, transfer pricing documentation

There is a change to the deadline for preparation of mandatory transfer pricing documentation in Bulgaria.

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The new deadline is 30 June of the year following the year for which the documentation applies.

Amendments to the tax law, published 8 December 2020 in the official gazette, revise the transfer pricing documentation deadline. The revised deadline aligns with a change to the deadline for filing the annual corporate income tax return.

The deadline for preparation of the Master file will be within 12 months after the deadline for preparation of the Local file.

The first year for which mandatory transfer pricing documentation must be prepared is 2020. Accordingly, the Local file for 2020 must be prepared by 30 June 2021, and the Master file for 2020 must be available by 30 June 2022.

In the event that an amended corporate income tax return is filed, the Local file must be updated within 14 days following the submission of the amended return but no later than 30 September of the current year.

Local and Master files

Taxpayers will be required to prepare a Local file if, as of 31 December of the previous year, they satisfied or exceeded at least two of the following thresholds:

  • Net book value of assets—BGN 38 million (approximately €19 million)
  • Net sales revenue—BGN 76 million (approximately €39 million)
  • Average number of the personnel for the reporting period—250 employees

Entities that are part of a multinational group of companies and are required to prepare a Local file must also have a Master file available.

The rules address the scope of controlled transactions that must be documented in the Local file, and all taxpayers (even those not satisfying the above-listed thresholds) have a general obligation to prove the arm's length nature of their related-party transactions.


Read a December 2020 report [PDF 111 KB] prepared by the KPMG member firm in Bulgaria

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