On 10 July 2019, Bulgaria’s Council of Ministers approved two agreements with the United States allowing for the automatic exchange of country-by-country reports. The CbC report is one element of the three-tiered standardized approach to transfer pricing documentation proposed by the OECD in base erosion and profit shifting (BEPS) Action 13.
Bilateral agreements are necessary between third countries and the United States, as the US has opted to not sign the 2010 Multilateral Competent Authority Agreement, which enables signatories to automatically exchange these agreements.
According to the US Internal Revenue Service CbC reporting jurisdiction table, the competent authority agreement to allow automatic CbC report exchanges between Bulgaria and the US was in negotiation as of 3 July 2019, when the table was last reviewed or updated.
