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Bulgarian Parliament Moves Forward on Legislation to Implement ATAD Reverse Hybrid Mismatch Rules

25 January 2022

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Proposed Changes

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Bulgaria

The Bulgarian parliament approved the Bill Amending and Supplementing the Corporate Income Tax Act in its first reading on 20 January 2022. The main measure of the bill provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance Directive as amended (ATAD2). This includes that where one or more foreign entities are affiliated undertakings and collectively hold directly or indirectly 50% or more of the voting rights, the share capital, or the right to profits of a hybrid entity incorporated or established in Bulgaria that is not considered a taxable person in Bulgaria but is...