Exchange of information on multinational enterprises’ profits, reportable cross-border arrangements, and Bulgaria’s IT solutions – in focus on day 3 of the EU4PFM Study Visit

Today, participants continued exploring EU directives that regulate or facilitate the exchange of tax information in Bulgaria. The day began with a presentation by experts from Bulgaria’s National Revenue Agency, who outlined how the country exchanges information on the profits of multinational enterprises to ensure accurate taxation (DAC 4).

Later, participants also discussed the implementation of Directives DAC 5 and DAC 6. The former aims to provide access to information collected under anti–money laundering measures, while the latter requires the disclosure of potentially aggressive cross-border tax arrangements.

A cross-border tax arrangement is a tax consultation or structure that may pose a risk of tax evasion. Such arrangements are dynamic, complex, and constantly evolving in response to countermeasures by tax authorities. At the same time, Directive DAC 6 and the provisions of Bulgaria’s Tax Code summarise a number of hallmark indicators that, at the time of adoption, are considered typical for arrangements that may suggest tax evasion or abuse.

Ivan Antonov, Chief Legal Adviser of the Tax Treaties Directorate, presented these indicators to the Ukrainian delegation, along with the IT solutions that ensure the effective implementation of information exchange in Bulgaria.

The knowledge gained will help Ukrainian colleagues integrate the provisions of these directives into national legislation – supporting the country’s strategic goal of EU membership.