Recently, the Bulgarian Ministry of Finance issued a draft bill and submitted it for public comment. The draft law transposing the provisions of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements.
The reporting requirement mainly applies to intermediaries who design, market, organize or manage a reportable agreement. In some cases, the requirement may also be transferred to a taxpayer, even if an intermediary is required by law to maintain confidentiality, unless the taxpayer has consented to disclosure of the information. The law will enter into force on 1 July 2020, with reportable agreements open within 30 days from the date on which the agreement is made available for execution.
Non-compliance with the reporting obligations results in certain penalties, including penalties of BGN 5,000 to BGN 10,000 for not reporting an agreement and BGN 2,000 to BGN 8,000 for reporting inaccurate or incomplete information.
The deadline for comments on the draft law is 3 November 2019.
