Countries: Bulgaria

Bulgaria vs Rubbertek Bulgaria EOOD, April 2022, Supreme Administrative Court, Case No 3453

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By judgment of 22 May 2020, the Administrative Court upheld the complaint filed by “Rubbertek Bulgaria” and set aside an assessment for FY 2015-2016 issued by the tax authorities on the determination of the arm’s length income resulting from related party transactions. According to the Administrative court, the tax assessment was unfounded and unsubstantiated. An appeal was filed by the tax authorities with the Supreme Administrative Court in which the authorities stated that the decision […]

Bulgaria vs CBS, March 2022, Supreme Administrative Court, Case No 3012

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By judgment of 22 May 2020, the Administrative Court set aside a tax assessment in which CBS International Netherlands B.V. had been denied reimbursement of withholding tax in the amount of BGN 156 830,27 related to royalties and license payments. An appeal was filed by the tax authorities with the Supreme Administrative Court. In the appeal the tax authorities held that the beneficial owner of the licence and royalty payments was not CBS International Netherlands […]

Bulgaria vs Central Hydroelectric de Bulgari EOOD, July 2021, Supreme Administrative Court, Case No 8331

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By judgment of 19 January 2021, the Administrative Court upheld an assessment for FY 2012-2017 issued by the tax authorities on the determination of the arm’s length income resulting from related party transactions. The tax assessment resulted from disallowed deductions for Intra group services provided under a general administrative, legal and financial assistance contract of 22 October 2012 Costs invoiced for the preparation of consolidated accounts Expenses related to “Technical services” for which no explanations […]

Bulgaria vs Montupet, January 2021, Supreme Administrative Court, Case No 630

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Montupet EOOD is a Bulgarian subsidiary in the French Montupet Group which specializes in the production of aluminum components for the automotive industry. In February 2016, the French Group became part of the Canadian LINAMAR Group, which specializes in the manufacture and assembly of components for the automotive industry. The French group and its production facilities (plants in France, Bulgaria, Northern Ireland, Mexico and Spain) retained their core business as part of one of LINAMAR’s […]

Bulgaria vs CBS, October 2020, Supreme Administrative Court, Case No 12349

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By judgment of 22 May 2020, the Administrative Court set aside a tax assessment in which CBS International Netherlands B.V. had been denied reimbursement of withholding tax related to royalties and license payments. An appeal was filed by the tax authorities with the Supreme Administrative Court. In the appeal the tax authorities held that the beneficial owner of the licence and royalty payments was not CBS International Netherlands B.V. but instead CBS CORPORATION, a company […]

Bulgaria vs “Beltart Manufacturing”, May 2020, Supreme Administrative Court, Case No 5756

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“Beltart Manufacturing” is a Bulgarian toll-manufacturer of of clothing accessories – trouser belts etc. – and is a member of the German Beltart Group. The remuneration for the manufactoring services provided to the group for 2013 and 2014 had been lower than for previous years. According to the company this was due to changes to the contractual and economic conditions and discounts. Following an audit the tax authorities came to the conclusion that the remuneration […]

Bulgaria vs KEY END ES ENERGY, April 2020, Supreme Administrative Court, Case No 4972

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Key End Es Energy concluded a share purchase and sale agreement of 20.12.2012 with a related party LUKERG BULGARIA GmbH, under which KEY END EU ENERGY transferred to its parent company LUKERG BULGARIA GmbH the ownership of the shares in eight subsidiaries. The subsidiaries owned a total of 15 wind turbines for the production of electricity and operated them on the Bulgarian energy market. According to the Purchase and Sale Agreement the price of the […]

Bulgaria vs “Telecom Bulgaria”, November 2018, Supreme Administrative Court, Case No 13993

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In 2004, a Management Services Agreement was concluded between Telecom Bulgaria (BTC EAD) and BTC Holding Limited, UK (the Operator), whereby the Operator was entrusted with supporting the overall management activities of the company, including the development and implementation of a general company performance policy, organisational structure, annual budgets, Strategic Plan and Business Plan. According to the contract it is agreed that for the services received Telecom Bulgaria shall pay to the operator a remuneration […]

Bulgaria vs “B-Production”, August 2017, Supreme Administrative Court, Case No 10185

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“B-Production” is a subsidiary in a US multinational group and engaged in production and sales. “B-Production” pays services fees and royalties to its US parent. Following an audit, the tax authorities issued an assessment where deductions for these costs had been reduced which in turn resulted in additional taxabel income. An appeal was filed by “B-Production” with the Administrative court which in a judgement of June 2015 was rejected. An appeal was then filed by […]

Bulgaria vs “K-Bul”, March 2016, Supreme Administrative Court, Case No 2690

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K-Bul is a Bulgarian subsidiary in the K Group. In the years 2007 to 2013 certain financial intra-group contracts were entered (Two financial service contract – concluded on 02.10.2007 and a Loan agreement concluded on 26.01.2010). Following an audit, the market interest rate was determined by the tax authorities on the basis of the Bulgarian National Bank (BNB)’s interest rate statistics published on the Bank’s website, and for the first two contracts a market interest […]

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