Corporate taxation

Corporate taxation

Our assistance includes: 

• advisory in the areas of corporate income tax, tax on expenses and withholding tax;
• review/preparation of annual
• corporate income tax returns;
• review/preparation of withholding
• tax returns, incl. for recalculation and refund of withholding tax - for more information see below.

Under the Bulgarian tax legislation EU/EEA
tax resident entities may choose to claim a refund of withholding tax paid in
Bulgaria on gross basis by recalculating it on a net basis for the following
types of income:

• Interest payments
• Royalty payments
• Technical service fees
• Franchising and factoring
• Rental fees (movable property)
• Management and control fees
• Income/capital gains from lease or disposal of immovable property
• Capital gains from disposal of financial assets

Local Taxes and fees

Our tax experts can help you optimize your real estate tax and garbage collection fee.

Our assistance includes:

• analysis of the filed declarations under the Local Taxes and Fees Act;
• validation of the calculated tax value of the immovable properties;
• verification of the obligations for garbage collection fees;
• recommendations for optimization and reduction of the liabilities.

Transaction Planning

Our tax experts, specialized in different industries, can advise on options to structure your transactions tax efficiently while keeping with the pursued business objectives and the applicable laws. Our expertise and assistance cover a full range of structure change issues such as: liquidation, corporate reorganization, tax and legal relocation of foreign companies and structures as well as various business transactions. Our services will help you identify potential tax savings, manage risks, improve efficiency, and enhance tax compliance.

Mergers and Acquisitions

Whether you plan to acquire shares in a Bulgarian company or perform a merger or ademerger, our tax specialists can help you organize the transaction in a waythat leads to optimal tax results. Our services related to acquisitions includecarrying out tax due diligence reviews, assessing the tax compliance status ofthe business being acquired or sold, identifying, and quantifying the relevanttax exposures.

International Tax Structuring

Deloitte has a long record of helping multinational enterprises develop and implement a business structure that optimizes their global tax position. Our large international network of professionals and resources enables us to offer innovative tax structuring solutions tailored to each client’s specific business and needs. Deloitte assists with foreign tax credits, income repatriation, effective tax rate forecasting, risk management and tax post-merger integration along with the necessary procedures. 

Application of Tax Treaties

Deloitte experts provide full range of tax services related to international taxation through which multinational companies can align their strategies with the specific business requirements. We can provide assistance and advice regarding the application of double tax treaties in Bulgaria, including all related procedures and formalities. Our broad array of services include interpretation of DTTs and advisory on issues such as permanent establishment, tax treatment of various international transactions and assistance with application of double tax treaty reliefs.

Assistance with international tax compliance

In a global strive for financial transparency, compliance with international tax filing and disclosure requirements is becoming ever more challenging: as the scope of reportable and publicly available data expands, companies seek out a trusted partner in managing their growing administrative workload. Deloitte’s tax professionals offer a full suite of international tax services, such as: assistance with mandatory transparency requirements, including the disclosure of cross-border transactions in accordance with the EU’s Mandatory Disclosure Rules (DAC6), the OECD’s Common Reporting Standard (CRS), and FATCA.

• FATCA
  Adopted by the US Congress, effective July 1, 2014, the Foreign Account Tax Compliance Act’s main purpose is to identify, deter and prevent tax evasion by U.S. citizens or residents who directly or indirectly invest outside the United States through foreign financial institutions. Virtually all foreign financial intermediaries and withholding agents that own or hold investments in an increasing number of countries are subject to information reporting and disclosure requirements of Foreign Account Tax Compliance Acts (FATCA) legislation. This type of legislation impacts organizations' tax functions, technology systems, operations, and business strategy. As a leading advisor in both tax and technology, Deloitte professionals are well positioned to help companies assess and address implications related to compliance with FATCA legislation. 
  
  
• Mandatory disclosure rules
  With a new EU regime increasing the level of transparency surrounding potential loopholes and harmful tax practices and stricter disclosure rules now applicable, businesses and individual taxpayers are in need of a trusted advisor to help identify reportable cross-border arrangements and file the necessary information to local tax authorities. Deloitte’s professionals will also help you raise awareness at board level and establish a plan for reliable information disclosure procedures within the company structure and minimize risks for non-compliance.
  
  
• Common Reporting Standard (CRS)
  Similar to FATCA, the CRS requires all financial institutions resident in a participating jurisdiction to identify and report any reportable accounts (typically persons tax resident in a CRS participating jurisdiction). Deloitte will offer reporting support and technical review services to help you avoid potential commercial, reputational, and financial risks (e.g., withholding and regulatory penalties) of non-compliance.