Bulgaria–MNE Tax

Africa

OECD updates and expands transfer pricing country profiles

December 13, 2021

The OECD today released updated transfer pricing country profiles for 21 countries, including three countries for which it has not previously published profiles: Albania, Kenya, and . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Bulgaria

EU advocate general opinion addresses withholding tax on unpaid interest

October 11, 2021

Stoycho Dulevski, Kolev, Angelov & Miteva Law Firm, discusses the September 30 EU Advocate General’s opinion regarding the assessment of withholding tax on unpaid interest in Case С-257/20 Vivacom Telecom Bulgaria, focusing on the . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Bulgaria

Bulgaria, Netherlands sign new tax treaty: The Sofia Globe→

September 14, 2020

Americas

OECD releases reports assessing cross-border tax dispute resolution in seven countries

November 29, 2019

OECD, on November 28, released peer review reports assessing cross-border tax . . .

Bulgaria

Bulgaria’s balanced Budget 2020 adopted on first reading by parliament

November 26, 2019

Ivan Dimitrov, in-house legal counsel in Sofiа, Bulgaria, discusses Bulgaria’s balanced budget draft law for 2020, adopted by Parliament on November 12 . . .

EU finance ministers urge adoption of aviation tax

November 11, 2019

Finance ministers from 9 European nations on November 7 called on the European Commission to advance a proposal for . . .

Bulgaria

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

October 28, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses a European Court of Justice Advocate General opinion concerning a Bulgarian law that excludes from the exemption from withholding taxes dividends paid by subsidiary companies incorporated in a Member State to their parent companies incorporated in Gibraltar . . .

Bulgaria

Bulgarian mandatory transfer pricing documentation rules enacted

August 23, 2019

Ekaterina Aleksova, Senior Manager at PricewaterhouseCoopers Bulgaria discusses a new law introducing mandatory transfer pricing documentation in Bulgaria which was officially published in early August . . .

Asia-Pacific

Pakistan, Bulgaria sign tax treaty: Faisal Saeed / TechJuice→

May 22, 2019

Americas

US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives

December 19, 2016

The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .

Bulgaria

Bulgaria proposes its first transfer pricing documentation rules

November 8, 2018

Bulgarian tax practitioner, Ivan Dimitrov, discusses a draft law presented for public discussion on November 5 by the Bulgarian government that would require multinationals to prepare transfer pricing documentation . . .

Bulgaria

Bulgaria tax changes introduce first CFC rules, modify thin cap provisions

December 4, 2018

Ivan Dimitrov discusses important tax changes introduced in Bulgaria last week, including the country’s first-ever controlled foreign company (CFC) rules and revisions to the thin capitalization regime . . .

Bulgaria, Cyprus, Portugal must comply with exchange of tax ruling directive, Commission says

July 13, 2017

The EU Commission today called on Bulgaria, Cyprus, and Portugal to transpose into their laws EU measures requiring the automatic exchange of tax rulings between EU tax authorities . . .

Americas

OECD seeks feedback on cross-border tax dispute resolution in eight countries

November 15, 2018

The OECD today asked taxpayers to provide feedback on their experiences with cross-border tax dispute resolution . . .

Bulgarian law charging interest on unpaid withholding tax violates EU law, court says

July 31, 2018

The European Court of Justice, in a decision issued July 25, struck down a Bulgarian law that requires interest to be paid on unpaid withholding tax only in cross-border situations and that provides that the interest is not recoverable, writes Davide Anghileri of the University of Lausanne . . .

Momentum builds for new EU tax on internet company revenue

September 17, 2017

Most EU nations now back a plan to tax digital company revenues as a stopgap measure until global agreement is reached on new international tax rules for the digital economy. Finance ministers from Austria, Bulgaria, Greece, Romania, Slovenia . . .

Americas

US negotiating with Bulgaria, Gibraltar for exchange country-by-country reporting data on MNEs

October 9, 2018

The US is negotiating with Bulgaria and Gibraltar to annually exchange country-by-country reports . . .

Bulgaria

UK tax treaties with Croatia, Bulgaria, Kosovo enter into force

January 8, 2016

The UK’s HM Revenue & Customs on January 8 announced that tax treaties with Croatia, Bulgaria, and Kosovo have entered into force. The UK’s tax treaty with Croatia entered into . . .

Bulgaria

UK and Bulgaria sign double tax treaty

March 30, 2015

The UK’s HM Revenue and Customs on March 30 announced that the UK and Bulgaria signed a double tax treaty on March 26. The agreement will enter into force . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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