Bulgaria Transfer Pricing Documentation Requirements
Bulgaria requires a mandatory Local File where a taxpayer meets at least two of three size thresholds, and a Master File where the group prepares one. Documentation is produced within 14 days of a request, and the Local File penalty is geared to the value of the related-party deals.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Taxpayers obliged to prepare a Local File and part of a multinational group | By the Local File deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 14 days. | BG | Yes (BGN 5,000 to BGN 10,000) |
Local File Required | At least two of: assets > BGN 38m, net sales > BGN 76m, or ≥ 250 employees | By tax return due date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 14 days. | BG | Yes (up to 0.5% of the documented related-party deals) |
CbC report Required | Group revenue ≥ BGN 1,467m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Bulgaria deadline
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Scope of the documentation obligation
A Bulgarian taxpayer must prepare a mandatory Local File where, as of 31 December of the previous year, it met at least two of three thresholds: a net book value of assets above BGN 38 million, net sales revenue above BGN 76 million, or an average headcount of at least 250 persons. A taxpayer obliged to prepare a Local File and forming part of a multinational group must also have available a Master File prepared by the ultimate parent or another group member. Documentation is produced within 14 days of a request. A taxpayer below the Local File thresholds has no mandatory documentation obligation, although adjustment-related penalties can still apply.
Distinctive features of the Bulgarian regime
The defining feature of the Bulgarian regime is the value-based Local File penalty paired with a clean threshold cut-off. Where a taxpayer is obliged to prepare a Local File and fails to do so, the penalty reaches up to 0.5 percent of the related-party deals subject to documentation, while the Master File penalty is a fixed band of BGN 5,000 to BGN 10,000. Below the Local File thresholds, no documentation-specific penalty applies, so the obligation and its sanction switch on together at the threshold. There is no transfer-pricing-specific return, and no published safe harbour.
Benchmarking and comparables
Comparable data may be drawn from internal and external transactions, with the source database required to be publicly available, and recognised sources include national statistical data, local industry associations, and the standard commercial databases. Multi-year testing, usually over three years, is the jurisdiction practice. Current guidance favours a fresh benchmarking search each year, with documentation prepared for the fiscal period in which the analysed transactions were concluded, although a prior study may be used for following years where the organisation, functions, and other pricing factors are unchanged. The general limitation period for corporate income tax is five years from the year following the filing term.
Frequently asked questions
When does a Bulgarian taxpayer have no mandatory documentation obligation?
Where it does not meet at least two of the three size thresholds as of 31 December of the previous year. Below that level no documentation-specific penalty applies, although adjustment-related penalties can still arise.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.