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Bulgaria Circulates Letter Regarding Non-Reciprocal Status for CbC MCAA

07 January 2020

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Treaty Development

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Bulgaria-OECD

Bulgaria's National Revenue Agency (NRA) reportedly circulated a letter to taxpayers in December 2019 regarding Bulgaria's status as a non-reciprocal jurisdiction for Country-by-Country (CbC) report exchange purposes under the CbC MCAA, which means Bulgaria will exchange CbC reports submitted in Bulgaria to other jurisdictions but will not receive CbC reports submitted in other jurisdictions under the MCAA (reciprocal exchange in the EU will still take place). The letter includes that until reciprocal exchange is established, CbC reports will be requested via bilateral agreements. Further, with respect to the 2018 reporting fiscal year, constituent entities of MNE groups in Bulgaria will...