Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

Bulgaria

Recent developments relating to MAP in Bulgaria prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• Entry into force of the MLI for Bulgaria’s tax treaties in 2023.

• Ongoing bilateral negotiations with Malta and Switzerland. Bulgaria has proposed to start negotiations for a new treaty to be considered by Italy.

Other developments relating to MAP

• No developments were reported

Latest Action 14 Peer Review report

18 October 2021 - https://doi.org/10.1787/8e7b2363-en

Tax treaty network of Bulgaria

• 70 treaties, applicable to 71 jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: in force.

Table 1. State of play of Bulgaria's tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
65	3	2

Source: OECD

Bulgaria's MAP programme

Organisation of competent authority function

• 14 persons:

  • one head of unit

  • 11 persons working on MAP cases (all of them work on other tasks as well):

    • all of the 11 employees work on other cases and three of these 11 also work on attribution/allocation cases.

• contact persons for MAP requests:

  • Director, Tax Treaties Directorate

    National Revenue Agency

    52 Dondukov Blvd. 1000 Sofia, Bulgaria

    Tel: + 359 2 9859 3061 Email: [e-mail].

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	Guidance, March 2019	https://old.nra.bg/en/page?id=711 (Section V to be referred to for form and content of a MAP request, including information requirements)
MAP profile	2 February 2021	https://www.oecd.org/tax/dispute/bulgaria-dispute-resolution-profile.pdf

Overview of Bulgaria's MAP Statistics for 2022

Please refer to https://www.oecd.org/tax/dispute/map-statistics-bulgaria.pdf for details with respect to Bulgaria's MAP Statistics.

Figure 2. Cases closed in 2022

Source: OECD

Figure 3. Evolution of Bulgaria's MAP caseload (2016-22)

Source: OECD

Table 3. Overview of Bulgaria’s MAP caseload for 2022

Inventory for year 2022	Opening Inventory 1/1/2022	Cases started	Cases Closed	End Inventory 31/12/2022
Attribution/allocation cases	3	6	1	8
Other cases	8	4	4	8
Total	11	10	5	16

Source: OECD

Table 4. Bulgaria’s average time to resolve MAP cases in 2022

Cases resolved in year 2022	Pre-2016 cases		Post-2015 cases		All
	Number of cases	Average time	Number of cases	Average time	Number of cases	Average time
				Start to End
Attribution / Allocation cases	0	N/A	1	6.44	1	6.44
Other cases	0	N/A	4	27.88	4	27.88
All cases	0	N/A	5	23.59	5	23.59

Source: OECD