On 11 December 2020, the Bulgarian Government published the amendments to the Act on Tax and Social Security Procedure Code (TSPC) in the State Gazette. The National Assembly adopted an Act amending and supplementing the TSPC. According to the amendments of Art. 71d, para. 1 of the TSSPC (adopted by the VAT Act), a new deadline has been set for the preparation of the transfer pricing documentation from 31 March to 30 June of the following year. The changes are in line with the introduced new deadline for filing annual corporate income tax returns under the CITA, which is also 30 June of the next year.
In Bulgaria, the master file shall be prepared within a 12-month period after the expiration of the deadline for the preparation of the local file. The first year for which mandatory transfer pricing documentation must be prepared is 2020. With the amendment, the new due date for preparing Local file for 2020 will be 30 June 2021 instead of 31 March 2021, and in the same way, the Master file for 2020 must be prepared by 30 June 2022.
On the other hand, in case of an amended corporate income tax return is filed, the Local file must be updated within 14 days following the submission of the amended return but no later than 30 September of the current year.
