On 5 June 2019, the Bulgarian Parliament adopted at first reading amendments to the Tax and Insurance Procedure Code, which introduced the new transfer pricing (TP) documentation requirements.
One of the most important changes is in relation to the requirements to prepare documentation in respect of loan transactions. This includes that documentation must be prepared if the total amount of loans received or granted exceeds BGN 1 million (originally proposed BGN 2 million) or the total amount of accrued interest and other related receipts and expenses exceeds BGN 50,000 (originally proposed BGN 100,000).
Another change is that the documentation preparation threshold for other categories of transactions is generally applied per transaction rather than aggregated amounts, although aggregation may still apply in certain cases. The date of entry into force of the mandatory documentation will also be changed so that the requirements will apply from 2020 instead of 2019, as originally proposed.
The proposal will then be approved by the Parliament at second reading.
