The Bulgarian Ministry of Finance is reportedly consulting on draft legislation for the implementation of certain measures of the EU Anti-Tax Avoidance Directive (ATAD). This includes: The introduction of an interest limitation rule that would limit the deduction of interest expense with both related and unrelated parties to 30% of EBIDTA, with excess interest allowed to be carried forward indefinitely and a safe harbor exemption of BGN 500,000 per year; and The introduction of controlled foreign company (CFC) rules in line with ATAD, including that a foreign entity or permanent establishment (PE) will be treated as a CFC if a...