GloBE Country Guide: Bulgaria

Summary

Status Enacted Law
LawOn December 22, 2023, the Law Amending the Corporate Income Tax Act (to implement the EU Minimum Tax Directive), was published in Issue 106 of the Official Gazette.

On September 18, 2024, the Bulgarian Ministry of Finance published for public consultation draft legislation to amend the Bulgarian minimum taxation rules.
Effective DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursTransitional CbCR Safe Harbour, QDMTT Safe Harbour and the Simplified Calculation Safe Harbour for Non-Material Constituent Entities. The Transitional UTPR Safe Harbour is included in the September 2024 Draft Law.

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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