Bulgaria Implements BEPS Pillar Two Rules, Leading to Effective Tax Cost Uplift for MNEs

Abstract

In this note, the author describes and comments on the draft proposal for an amendment to the Bulgarian Corporate Income Tax Act to transpose the EU Minimum Taxation Directive (2022/2523). This reflects the OECD’s initiative to introduce a global minimum tax rate of 15% for large-scale groups (the Pillar Two solution). Bulgaria is one of the few EU Member States with a headline tax rate of less than 15% and, as such, the amendment will have a significant impact.