On 26 September 2023, the Bulgarian Ministry of Finance released a draft law for the implementation of the Pillar 2 global minimum tax rule in accordance with EU Council Directive 2022/2523 of 14 December 2022. The draft law is currently subject to a public consultation and the deadline for comments is 26 October 2023.
According to the Government’s explanatory statement, the draft law follows the EU Council Directive No. 2022/2523. This directive is designed to enact the Organization for Economic Co-operation and Development (OECD) Pillar 2 rules within the European Union. This directive is designed to enact the Organization for Economic Co-operation and Development (OECD) Pillar Two rules within the European Union. The Draft Law includes the under-taxed profits rule (UTPR), income inclusion rule (IIR), and the Qualified Domestic Minimum Top-Up Tax (QDMTT).
The IIR and QDMTT will apply from the financial year beginning on or after 1 January 2024 and UTPR will apply from the financial year beginning on or after 1 January 2025.
