Bulgaria fully follows and applies the OECD Transfer Pricing (TP) guidelines and has had robust TP rules for several years, but taxpayers must be concerned about the regulations. The TP rules were first announced in the Corporate Income Tax Act (CITA), Tax and Social Security Procedures Code (TSSPC), and the Ordinance No H¬9 for implementing the TP methods and it was issued on 29th August 2006 by the Ministry of Finance. Following international trends, a manual guidance regarding TP issues had published by the National Revenue Authority (NRA) in 2010.
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