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Bulgaria Approves CbC Exchange Agreements With US

by Ulrika Lomas, Tax-News.con, Brussels

08 August 2019


Bulgaria's Council of Ministers earlier this month approved two agreements with the United States allowing for the automatic exchange of country-by-country reports.

The CbC report is one element of the three-tiered standardized approach to transfer pricing documentation proposed by the OECD in base erosion and profit shifting (BEPS) Action 13.

Bilateral agreements are necessary between third countries and the United States, as the US has opted to not sign the 2010 Multilateral Competent Authority Agreement, which enables signatories to automatically exchange these agreements.

According to the US Internal Revenue Service CbC reporting jurisdiction table, the competent authority agreement to allow automatic CbC report exchanges between Bulgaria and the US was in negotiation as of July 3, 2019, when the table was last reviewed or updated.

The table also states that the Bulgarian Tax Administration is contacting constituent entities in Bulgaria to discuss local filing requirements.

TAGS: tax | Bulgaria | agreements | transfer pricing | United States | Tax | BEPS

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