author_orbitax
Orbitax

Share This Article

Bulgaria Publishes Legislation to Implement New Interest Limitation and CFC Rules

03 December 2018

|

Approved Changes

|

Bulgaria

On 27 November 2018, Bulgaria published the Law of 22 November 2018 in the Official Gazette, which includes various amendments to the Corporate Income Tax Act, including the introduction of new interest limitation and controlled foreign company (CFC) rules in accordance with the EU Anti-Tax Avoidance Directive (ATAD). The main points of the interest limitation rules include: The rules limit the deduction of net interest expense and other equivalent costs and related financing costs to 30% of EBIDTA; Excess interest expense/costs may be carried forward indefinitely, subject to the same 30% of EBITDA limit; A safe harbor exemption is provided...