Page 12 - CEE Tax Guide 2024
P. 12

Bulgaria                                                                                                               printed or handwritten music editions), and periodical   Services exempt from VAT include financial and insurance
                                                                                                                                                                                      services, transfer of buildings and certain parcels
                                                                                                                                  printed works such as newspapers and magazines.
                                                                                                                                  3. Provision of baby and small children's food, baby   of land and rights related thereto, letting of real estate
                                                                                                                                  diapers and similar items for baby hygiene according   to individuals for housing, postal services and postage
                                                                                                                                  to Appendix No. 4.                                  stamps, educational services, gambling, supplies, culture,
                                                                                                                                                                                      religion, medical and social services, and supplies for
                               Mazars OOD                                                                                                                                             which no tax credit was used.
                               3A Moscovska str.,                                                                                  VAT options in         Applicable / limits         VAT payers are required to submit monthly VAT returns,
                               1000 Sofia, Bulgaria                                                                                Bulgaria                                           sales and purchase registers, VIES, and Intrastat returns.
                               Phone: +359 287 800 02                                                                              Distance selling           EUR 35,790/year         Other indirect taxes include excise duties (on mineral oils,
                               www.mazars.bg
                                                                                                                                   Call-off stock                  No                 spirits, beer, wine, tobacco and tobacco products, natural
                                                                                                                                   VAT group registration          No                 gas, electricity, and solid fuels).
                                                                                                                                   Cash accounting – yearly   EUR 500,000/preceding 12 months  Personal income tax / Social security system
                                                                                                                                   amount in EUR (approx.)
                                                                                                                                   Import VAT deferment            No                 Personal income tax is applied at a flat rate of 10% on most
           Corporate taxes and other direct taxes              royalties are paid in favor of a parent company registered                                 All types of waste (construction,   of the income. The tax rate for dividends or liquidation
                                                               in an EU Member State.                                                                    household, production, hazardous);   shares paid in favor of a natural person is 5%.
           Bulgaria has a flat corporate income tax rate of 10%,   Local taxes are determined by each municipality within          Local reverse charge  services related to waste processing;   The tax rate for amounts received from the expiry of life
           which is applied to the annual tax profit. The tax profit   the ranges stated in the Law of Local Taxes and Fees. Local                      various types of agricultural production   insurance, if its duration was more than 15 years, is 7%.
           may be reduced by tax losses carried forward within   taxes and fees include:                                                                      (seeds and grain).      Income from employment and self-employment is subject
           five subsequent financial years. Bulgaria applies thin     • real estate tax: the tax rate is in the range of 0.1%      Option for taxation                                to social security and health insurance contributions. In the
           capitalization rules to interest expenses from loans   to 4.5%. The base for taxation of non-residential real               letting of real estate      ü                  case of employment, the employee’s contribution amounts
           or leasing provided or guaranteed by related parties.  estates of companies is the higher of the book value                                                                to 13.78% (10.58% social security and 3.2% health
           The financial results of collective investment schemes and   or the value calculated by municipality tax valuation.     supply of used real estate      ü                  insurance). For the employer, this contribution is 18.92%
           enterprises with special purposes are not taxable through   The base for taxation of all residential real estate is the   VAT registration    Approx. EUR 51,130/last 12 months    (14.12% and 4.8%, respectively). There are different
                                                                                                                                                              (till 12/31/2024).
           corporate income tax.                                 municipality’s tax valuation;                                     threshold             Approx. EUR 84,875/last 12 months   contribution rates for specific positions involving higher
           Advance tax payments should be made each month        • transportation vehicle tax: determined as an exact                                        (from 01/01/2025).       risk (miners, pilots, workers in chemical and other harmful
           or quarter, based on the estimated tax profit for the   amount, depending on vehicle type and power;                   4. Until December 31, 2024, for deliveries with a place   production facilities, etc.).
           current year.                                         • gift tax: applied to gifts of all kinds, with very limited     of performance on the territory of the country: restaurant   For each position, a minimal base is determined for social
           Withholding tax rates are 5% for dividends and 10%    exemptions. Applies also to forgiven payables. There             and catering services.                              and health contributions (mostly distributed by sectors
           for interests and royalties (double taxation treaties   are two ranges of rates applicable: between 0.4% and           5. Until June 30, 2024, the provision of the following with   of the economy). The maximum assessment base for social
           between Bulgaria and other countries can also be applied   0.8% for gifts between siblings and their children; and     a place of performance within the territory of the country:   and health insurance contributions is BGN 3,750 (approx.
           in order to decrease the withholding tax rate). There   between 3.3% and 6.6% for all other gifts;                     provision of a general tourist service and supply of service   EUR 1,918).
           is no withholding tax if the dividends, interests, and
                                                                 • tax on the acquisition of property for a consideration:        for use of sports facilities.
                                                                 applies to real estate, vehicles, and limited real estate
            Transfer pricing in Bulgaria                         rights acquired for a consideration. The tax rate range                                                                                           Average wage
            Arm's length principle   ü      Since 1989           is between 0.1% and 3% of the value of the property,              Wage related taxes in Bulgaria                      Minimum wage               in private sector
                                                                 or, in the case of exchange, the value of the more
                                      A TP local file is obligatory for                                                            Exchange rate BGN/EUR                                                   1.96  in EUR  in BGN  in EUR  in BGN
                                      companies that have exceeded   expensive property;
                                       at least two of the following     • inheritance tax: exempt to a limited extent                                                                    477         933           1,029          2,012
                                        indicators by December   (family members);
            Documentation liability  ü  31 in the previous year: assets                                                            Total wage cost                                        567        119%           1,223       119%
                                         over BGN 38 million,      • patent tax: applied to micro enterprises or individuals                        Social security contribution - employer    67      14%           145         14%
                                      revenues over BGN 76 million,   whose activities are small services such as tailoring, very
                                         over 250 employees.     small stores, carpentry, etc. These are fixed amounts,                                     Health insurance - employer    23          5%             49          5%
            APA                 No             –                 determined by each municipality;                                  Gross salary                                           477        100%           1,029      100%
                                                                 • a wide range of other fees (such as tourist tax; tax on the
            Country-by-Country                 –                 carriage of passengers by taxi; refuse collection fee)                                       Employees' contributions     66         14%            142         14%
            liability            ü                               or other fees usually imposed for specific services, such         Calculated personal income tax after employees' contributions   41      10%        89         10%
            Master file-local file       Where the company       as social services, technical and other services, renting         Net salary                                             370         78%
                                         required to prepare
            (OECD BEPS 13)       ü      an LF is an MNE member,                                                                                                                                                      798         78%
            applicable                  it must also have an MF.  of plots for sale at marketplaces, pavements, etc.
            Penalty                                            VAT and other indirect taxes
                                      0.5% of the transaction amount
                                       – for lack of local file; BGN
              lack of documentation   ü  5,000 to BGN 10,000 penalty –   For 2024, the standard VAT rate is 20% and the reduced
                                                               rate is 9%. The tax rate is 9% for:
                                        for lack of a master file.
                     tax shortage  ü    BGN 1,500 to BGN 5,000  1. Provision of accommodation services in hotels and
                                                               similar facilities, including the provision of holiday
            Related parties    > 50%    Direct or indirect control   accommodation and the rental of campsites or caravans,                      Iliya Tsvetkashki
                                         or personally related.
                                                               with a place to perform on the territory of the country.                          Chief Accountant
            Safe harbors        No             –               2. Provision of books on physical or electronic media, or both                    Phone: +359 287 800 02
            Level of attention paid by Tax                     (including textbooks, educational books and study sets,                           E-mail: iliya.tsvetkashki@mazars.bg
            Authority                        9/10              children's books with illustrations, for drawing or coloring,

           12    Mazars                                                      Central and Eastern European tax guide 2024          Central and Eastern European tax guide 2024                                             Mazars   13
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