Bulgaria: Transfer pricing documentation; Local file for 2020 required by 30 June 2021
In general, all taxpayers have a general obligation to prove the arm’s length nature of their related-party transactions.
First year for which mandatory transfer pricing documentation must be prepared is 2020
The first year for which mandatory transfer pricing documentation must be prepared is 2020.
- The deadline is 30 June 2021 for preparing a Local file regarding the transfer pricing documentation for 2020.
- Entities that are part of a multinational group of companies and that are required to prepare a Local file must also prepare a Master file. The deadline is 30 June 2022 for preparing a Master file for 2020.
Taxpayers must prepare a Local file for 2020 if, as of 31 December 2019, they reported amounts exceeding at least two of the following three thresholds:
- BGN 38 million (approximately €19 million) net book value of assets
- BGN 76 million (approximately €39 million) net sales revenue
- Average number of the personnel for the reporting period of 250
In general, all taxpayers (even if not exceeding the above thresholds) have a general obligation to prove the arm’s length nature of their related-party transactions, and this is accomplished by preparing transfer pricing documentation.
Other measures address the scope of controlled transactions required to be reported and documented in the Local file.
If an amended corporate income tax return is filed for 2020, and this amended return results in any changes to the information provided in the Local file, then the Local file must be updated within a 14 days after the submission of the amended return (but not later than 30 September 2021).
Read a May 2021 report [PDF 103 KB] prepared by the KPMG member firm in Bulgaria
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.