1. Correction of errors:
Corrections of errors related to tax depreciable assets and errors in the transformation of the accounting financial result:
• Equalization of the tax treatment of these errors with the general procedure to correct accounting errors, namely tax financial results for the past years are adjusted in accordance with relevant laws in previous years so that though the error was not committed.
• Limit to correct the mistakes of previous years – The companies are not allowed to adjustment of the tax and financial result of the tax liability on him for this minala godina, which on 1 January of the year of detection of defects have passed at least 6 years. For comparison, before the change was applied to limit mistakes more than 5 years if they were not admitted would reduce the tax financial results.
Therefore in 2011 is not permissible to correct errors before 01.01.2005
2. Tax treatment in the distribution of dividends in kind
Dividends assets at the time of distribution for tax purposes are considered to be made at market prices and are written off. In determining the tax financial result, the accounting financial result increased by profits and reduced by the loss calculated as the difference between the market price of assets and their book value at the date of distribution of dividend.
3.Changes related to filing the annual tax return
The change applies to persons who have realized profits or income from sources abroad, respectively, have paid tax abroad – they must attach to their annual tax return evidence of the amount of taxes paid abroad. This requirement does not apply to gains or income from sources abroad, in respect of which agreement for avoidance of double taxation is provided a method for avoiding double taxation “exemption with progression.
7. An obligation for payers of the rental income of foreign legal entities to withhold and pay withholding tax. By 2010, the withholding tax on income from rent is imported from foreign persons – recipients of those benefits.
8. Introduction of tax at source on certain income accruing to foreign legal entities established in jurisdictions with a preferential tax regime (ie. Offshore) are from a source in the country:
-remuneration for services or rights, except where the services or the rights are actually granted;
-penalties and damages of any kind, except for benefits accrued under insurance contracts.
9. Reduce tax rate from 10% to 5% for interest income, royalties in both the following conditions:
the beneficial owner is a foreign legal entity from State – State of the Union or place of business in the country – member of the EU, the foreign legal entity from the country – the EU; local entity – payer of income, or the person whose place of business in Bulgaria is the payer of income is a person connected with the foreign legal entity – holder of income or a person whose place of business is the beneficial owner.
