Bulgaria Consulting on Legislation to Implement Interest Limitation and CFC Rules EU Anti-Tax Avoidance Directive

The Bulgarian Ministry of Finance is reportedly consulting on draft legislation for the implementation of certain measures of the EU Anti-Tax Avoidance Directive (ATAD). This includes:

• The introduction of an interest limitation rule that would limit the deduction of interest expense with both related and unrelated parties to 30% of EBIDTA, with excess interest allowed to be carried forward indefinitely and a safe harbor exemption of BGN 500,000 per year; and
• The introduction of controlled fo…