CMS Expert Guide to Mastering OECD's Pillar Two in Bulgaria

Key stages in the introduction of global minimum taxation

1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

The National Assembly is in the process of passing a law, introducing the Pillar Two rules, including the imposition of the Domestic Top-Up Tax from 1 January 2024.

3. Have the local tax authorities published guidelines commenting on Pillar Two/GloBE rules?

N/A.

4. When will the Income Inclusion Rule (IIR) come into force?

2024.

5. When will the Undertaxed Payments Rule (UTPR) come into force?

2025.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

2024.