Commercial Contracts

One of the constant challenges in commercial life is balancing the flexibility to take advantage of new business opportunities with the desire for reliable and robust…

Corporate, Mergers & Acquisitions

A flexible corporate structure is essential for regularly changing environments and business ambitions. Tascheva & Partner understands that so far as business…

Real Estate & Construction

Tascheva & Partner has been active in real estate and construction since the start of the privatization of state-owned properties and the opening of the Bulgarian…

Energy

We provide expert assistance to clients investing in energy projects in Bulgaria. We have a strong and proven track record advising on renewable energy projects. Our services…

Insurance

The insurance market is growing rapidly in Bulgaria and Tascheva & Partner is well equipped to offer top-level related legal services to its international and local…

Transfer pricing documentation requirements in regard with controlled transactions

Transfer pricing documentation requirements in regard with controlled transactions

On 05.11.2018 the Ministry of Finance introduced a bill for Amendment and Supplement of the Tax and Social Insurance Procedure Code. The bill seeks to implement Action 13 of the Base Erosion and Profit Shifting actions (the so-called BEPS actions) of the OECD.    The bill makes provision for obligations concerning local and foreign taxable legal persons which perform business activities in the Republic of Bulgaria through a place of business activity in the country, and which also carry out the so called “controlled transactions” on the territory of the country – i.e. they have commercial and financial relationships with Continue Reading

Amendments of the Tax and Social Security Procedure Code (TSSP) related to the automatic exchange of country by country reports

Amendments of the Tax and Social Security Procedure Code (TSSP) related to the automatic exchange of country by country reports

The Bulgarian Parliament adopted the draft amendments to the TSSPC regarding the automatic exchange of country by country reports (CbC reports) of multinational groups of undertakings (MGU), operating within several EU member states. The amendments are effective as of 04.08.2017. From 2017 the Bulgarian National Revenue Agency (NRA) will exchange information about MGU with the other tax administrations in the EU. One group of data will concern transfer pricing agreements and binding opinions. The changes of the TSSPC are implementing the regulations of Council Directive (EU) 2015/2376 of 8 December 2015. In Bulgaria this legal measure would affect mainly foreign Continue Reading

Amendments of the Tax and Social Security Procedure Code (TSSP) related to third parties liability for taxes or compulsory social-insurance contributions of legal entities

Amendments of the Tax and Social Security Procedure Code (TSSP) related to third parties liability for taxes or compulsory social-insurance contributions of legal entities

The changes implemented by the Act Amending and Supplementing the TSSPC, promulgated in the State Gazette №63/04.08.2017 aim to improve and complete the existing provisions on third party liability concerning outstanding taxes and social security contributions of taxable legal entities. The amendment of the provision of art. 19 and 20 of TSSPC is of importance for the optimization of proceedings and for defining clearly the preconditions which have to be proved so that secondary liability under the TSSC can be engaged. The new wording of art. 19 of TSSPC expands the range of individuals whose liability can be engaged. This Continue Reading

Draft amendments of the VAT Act with respect of the possibility of adjustment of credit for input tax

Draft amendments of the VAT Act with respect of the possibility of adjustment of credit for input tax

On the website of the Ministry of Finance are published draft amendments in order to adjust the tax acts in 2017. In the transitional and final provisions to the Act amending and supplementing the Excise duties and tax warehouses act is proposed the introduction of the following amendment of the VAT Act with respect of the possibility of adjustment of credit for input tax: A. Upon advance payment In case a supply is not effected and the supplier has failed to issue a credit note certifying the supply has not been carried effected, the recipient is obliged to adjust the Continue Reading

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