Recent developments in transfer pricing: audits, CbCR, court practice

Invitation for Deloitte Seminar

Bulgaria started to implement the decisions of the BEPS project and the related EU Directives in its internal legislation. The new country-by-country reporting (“CbCR”) rules require disclosing of the group KPIs to the tax authorities and will likely enable focused interest in the transfer pricing (“TP”) matters during audits and checks. Are you ready to handle the new TP environment?

Deloitte Bulgaria organizes an interactive seminar “Recent developments in transfer pricing: audits, CbCR and court practice”.

The main subjects for this seminar are as follows:

  • Bulgarian CbCR legislation – deadlines, questions to clarify;
  • Transactions questioned by the NRA and recent tax audits practices in the TP area;
  • Practical session: Court cases and solving a case study.




09:00 – 09:30

Welcome and registration of the participants in the seminar

9:30 - 11:00

  • CbC Reporting - what needs to be done? Which are the expected consequences? When CbCR should be filed by the Bulgarian entity?
  • Most common areas for discussion with the tax authorities? – loans, intragroup services, year-end adjustments, losses
  • Recent tax audit and tax check practices in the TP area - how to prepare?

11:00 - 11:30

Coffee break

11:30 - 13:00

  • Mutual agreement procedure as an alternative TP dispute resolution mechanism
  • Overview of the Bulgarian court practice on TP cases
  • Case study with local and international aspects

13:00 - 14:00


14:00 - 15:00

Q&A session – possibility to discuss questions with the Deloitte TP team

The seminar will have a practical approach and is meant for accountants, lawyers, finance specialists and managers.

As the seminar will have an interactive set-up, there will be over opportunity for asking question by you! Transfer pricing questions raised by e-mail on front will be answered with priority. 

The presentations will be done in Bulgarian and English language, with simultaneous translation in the other language.

Time, venue and fee

The seminar will take place at 17 October 2017 in Sofia Hotel Balkan, from 9:30 to 13:00. Right after the lunch, there would be one hour session for Q&As where the participants will have a chance to bring their own cases into discussion with one of the Deloitte transfer pricing team members.

Participation fee is EUR 80 (VAT excluded). For two or more participants from the same company, the fee is EUR 65 (VAT excluded) per 1 participant.

Please confirm your participation by sending completed registration form by 16th October 2017 to:

Silvia Valcheva,


tel: (02) 8023 395, (02) 8023 300.

We are looking forward to seeing you at the seminar!

Registration form

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