On 31 December 2019, Bulgaria published Law on Amendment and Supplementation of the Tax and Social Insurance Procedure Code in the Official Gazette. This Law includes measures to transpose an EU directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6). This Law enters into force from 1 January 2020 and the reporting requirements will enter into force on 1 July 2020.
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. 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.
