Bulgaria Consulting on Legislation to Implement Exit Tax and Hybrid Mismatch Measures of EU Anti-Tax Avoidance Directive

Bulgaria's Ministry of Finance has published for consultation a draft bill on amendments to the Corporate Income Tax Law for the implementation of the exit tax and hybrid mismatch measures of the EU Anti-Tax Avoidance Directive (ATAD1 and ATAD2). Subject to approval, the measures are to apply from 1 January 2020.

The exit tax measures provide that where a taxpayer transfers assets outside Bulgaria or changes its tax domicile to another jurisdiction, the deemed gain that arises will be subje…