The Ordinance updates transfer pricing rules and aligns them with the latest OECD guidelines.
Bulgaria’s Ministry of Finance (MoF) issued Ordinance H-3 of 7 November 2025, updating the country’s transfer pricing framework to align with the latest OECD Transfer Pricing Guidelines.
The ordinance was published in the State Gazette on 11 November 2025 and replaces Ordinance H-9 of 2006.
Ordinance H-3 sets out procedures for determining market prices, focusing on transfer pricing between related companies. It requires the use of the arm’s length principle, meaning prices in controlled transactions must match those in comparable uncontrolled transactions.
The ordinance outlines five main methods for price determination, including the comparable uncontrolled price method and the transactional net margin method. It also provides detailed guidance for conducting a transfer pricing analysis, including defining controlled transactions and performing comparability analyses.
It establishes rules for more complex transactions, such as intra-group services, intangible assets that are difficult to value, and financial operations like debt financing.
The ordinance highlights the need for thorough functional analysis and proper documentation to ensure compliance with tax rules.
Earlier, Bulgaria initiated a public consultation on its proposed draft regulations to update its transfer pricing regulations as part of its efforts to join the OECD.
