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Bulgaria Enacts State Budget Act for 2025 Including Updates for Pillar 2 Global Minimum Tax and New Standard Audit File for Tax Requirements

02 April 2025

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Approved Changes

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Bulgaria

Bulgaria published the State Budget Act for 2025 in the official gazette on 27 March 2025. Among other things, the Act updates the country's Pillar 2 global minimum tax legislation to incorporate OECD Pillar 2 administrative guidance issued in February 2023, July 2023, December 2023, and June 2024. This includes rules on the transitional UTPR safe harbor and Country-by-Country Reporting safe harbor, excess negative tax carryforward rules, rules on the allocation of taxes under blended CFC Regimes, rules on the treatment of transferable tax credits, and others. The Act also provides for the implementation of Standard Audit File for Tax...