On 20 January 2022, the Bulgarian Parliament passed the draft law amending and supplementing the Corporate Income Tax Act (CITA). The draft law provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance Directive as amended (ATAD2).
In addition to the reverse hybrid rules, the draft law also provides for the correction of the Bulgarian implementation of the ATAD-CFC rules which will be applied to all Bulgarian taxable persons that are subject to corporate income tax in the country and have CFCs regardless of their form of taxation subject to approval in the second and final reading, the measures in the draft law will apply from 1 January 2022.
