Corporate taxation

The corporate tax rate in Bulgaria is 10%.

Transfer pricing

Bulgarian transfer pricing rules are provided in the Corporate Income Tax Act (CITA), Tax and Social Security Procedures code, and in the Ordinance No H-9 for implementation of the transfer pricing methods. Although there is no specific reference to the OECD TPG in the Bulgarian TP legislation, it generally follows them. However, there are certain differences (e.g. there is a hierarchy of the methods under the Bulgarian legislation). The Bulgarian tax legislation requires that taxpayers determine their taxable profits and income by applying the arm’s-length principle to the prices for which they exchange goods, services and intangibles with related parties (i.e. transfer prices). Interest on loans provided by related parties should be consistent with market conditions at the time where the loan agreement is concluded.


Transfer Pricing Case Law

Case NameDescriptionDateCountriesKeywords