author_orbitax
Orbitax

Share This Article

Bulgaria Corrects and Clarifies CFC Rules

20 August 2019

|

Approved Changes

|

Bulgaria

Further to the measures on transfer pricing documentation and EU dispute resolution {News-2019-08-14/A/2-previously reported}, Bulgaria's recently published Law on Amendment and Supplementation of the Tax and Social Insurance Procedure Code also includes certain correcting and clarifying amendments to the controlled foreign company (CFC) rules that were introduced with effect from 1 January 2019 to comply with the EU Anti-Tax Avoidance Directive (ATAD). This includes the amendment of the provisions for the determination of a CFC to include that the CFC rules will not apply to: a taxable person who is taxed under the procedure of Part Five of the Corporate...