Bulgaria's Ministry of Finance has published for consultation a draft bill on amendments to the Corporate Income Tax Law for the implementation of the exit tax and hybrid mismatch measures of the EU Anti-Tax Avoidance Directive (ATAD1 and ATAD2). Subject to approval, the measures are to apply from 1 January 2020. The exit tax measures provide that where a taxpayer transfers assets outside Bulgaria or changes its tax domicile to another jurisdiction, the deemed gain that arises will be subject to tax. The exit tax only applies in relation to transfers between parts of the same enterprise and does not...