On 20 June 2019, the Ukraine State Fiscal Service published a guidance letter No. 2826/6/99-99-15-02-02-15/IPC defining the treatment of transactions with residents of tax Bulgaria, which was removed from the Cabinet tax haven list in April 2018.
The guidance provides that transactions with residents of Bulgaria in 2018 are considered controlled if-(i) if the annual income of the taxpayer within the reporting period exceeds UAH 150 million for the 2018 tax (reporting) year; and (ii) the sum of the transactions with a resident of Bulgaria exceeds UAH 10 million, carried out in the period from 1 January 2018 to 24 April 2018.
If the above conditions are met, transactions that executed between 1 January 2018 and 24 April 2018 with Bulgaria must be reflected in the annual controlled transactions report, which is due 1 October 2019 for the tax year of 2018.
