Bulgaria’s Council of Ministers approved the pending Intergovernmental Agreement (IGA) with the US regarding the exchange of Country-by-Country (CbC) reports.

Bulgaria’s Ministry of Finance signed a country-by-country (CbC) exchange agreement with the US on 30 May, 2024. This agreement will have an operative date that is yet to be determined.

The automatic exchange of CbC reports will enhance international tax transparency and aid tax administrations in targeting resources to identify, monitor, and address high-risk tax evasion cases by large multinationals.

The IGA stipulates that, according to Article 25 of the 2007 Bulgaria-US tax treaty, the Competent Authorities of both Parties will automatically exchange Country-by-Country (CbC) Reports annually.

To facilitate this, the two countries will establish a Competent Authority Arrangement (CAA) that outlines the specific details for exchanging Country-by-Country (CbC) reports. The exchange of these reports will only begin once the CAA is in effect.

In addition, all information exchanged shall be subject to the confidentiality and other protections in the Convention, including the provisions limiting the use of the information exchanged. In the event of termination of this Agreement, all information previously exchanged under this Agreement shall remain subject to such terms of the Convention.

In case any difficulties in the implementation of this Agreement arise, either Party may request consultations to develop appropriate measures to ensure the fulfilment of this Agreement.

This Agreement may be amended by written mutual agreement of the Parties. Unless otherwise agreed upon, such an amendment shall enter into force through the same procedures as set forth in paragraph 6 of this Agreement.