Tax treatment under the Corporate Income Tax Act in case of transfer of fixed assets to a place of business in Bulgaria

Foreign legal entities that carry out economic activity in Bulgaria through a place of economic activity, dispose of property in such a place of economic activity or receive income from a source in Bulgaria are taxable persons under the Corporate Income Tax Act and should form a tax financial result.

From 01.01.2020 in Bulgaria the rules for tax regulation are applied in case of transfers between a part of one enterprise located in the country and another part of the same enterprise located outside the country, which rules have been introduced in connection with the application of Directive (EU) 2016/1164 of the Council of 12 July 2016 laying down rules against tax avoidance practices which directly affect the functioning of the internal market (Directive 2016/1164).

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