The consultation is set to conclude on 23 October 2025.
Bulgaria has initiated a public consultation on its proposed draft regulations to update its transfer pricing regulations as part of its efforts to join the Organisation for Economic Cooperation and Development (OECD).
The proposed changes aim to enhance the country’s tax system by establishing detailed guidelines for transfer pricing analysis, fully aligning with the latest OECD standards, as per the explanatory memorandum.
The draft ordinance aims to replace Bulgaria’s 2006 transfer pricing rules with a new framework. It introduces detailed standards for identifying related-party transactions, conducting comparability analyses, and applying the most appropriate transfer pricing methods.
The Regulation outlines the application of five primary methods for determining arm’s length prices: the comparable uncontrolled price method, resale price method, cost plus method, transactional net margin method, and transactional profit split method.
Additionally, it permits the use of an alternative method under specific conditions. All methods must adhere to the arm’s length principle, ensuring that prices between related parties mirror those agreed upon by independent entities.
Key guidelines are provided for applying these methods, including selecting the most suitable approach, evaluating comparability factors (such as functions, assets, risks, contracts, economic conditions, and business strategies), and determining when to use internal versus external comparables.
The Regulation also addresses scenarios where multiple methods may be applied. A strong focus is placed on conducting a comparability analysis in line with the OECD Transfer Pricing Guidelines, ensuring consistency and fairness in pricing practices.
The ordinance has no negative financial impact and does not impose new administrative burdens.
The draft proposal was introduced for public consultation on 3 October 2025. Stakeholders have until 23 October 2025 to provide feedback.
