The IRS updated its Country-by-Country Reporting (CbCR) Jurisdiction Status Table on 11 March 2025, confirming that the competent authority arrangement between the US and Bulgaria became operative on 9 September 2024.
Country-by-Country Reporting (CbCR), which is the specific report for an entity referred to as a Country-by-Country or CbC report, is an international initiative led by the OECD. It sets a reporting standard for multinational enterprises (MNEs) with total consolidated group revenues exceeding EUR 750 million. It covers key tax-related details such as financial data, employee information, and non-cash tangible assets.
According to OECD guidelines, this information is exchanged between the tax authorities of the participating countries. However, the EU has passed legislation requiring Country-by-Country reports to be made publicly accessible after 2024.
Under this arrangement, both countries will automatically exchange CbC reports received from multinational enterprise (MNE) groups headquartered in their jurisdictions, provided they have taxable entities in the other country. The exchange is based on Article 6 of the 2007 Bulgaria-US tax treaty.
The agreement applies retroactively to fiscal years starting on or after 1 January 2016, with reports due within 18 months after the fiscal year-end. For fiscal years starting on or after 1 January 2017, the exchange deadline is 15 months. However, the first reports under this arrangement must be exchanged by 9 December 2024.
