Together with more than 60 other countries and jurisdictions on 7th June 2017 Bulgaria signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”). The document is subject to subsequent ratification at national level.
The MLI is the first multilateral treaty of its kind and marks a crucial milestone in the international tax agenda. By transposing the results from the OECD/G20 BEPS Project into bilateral tax treaties worldwide, the MLI offers concrete solutions for governments to close the gaps in current international tax regulations that allow corporate profits to “disappear” or to be artificially shifted to low or no tax jurisdictions. The MLI will modify existing bilateral tax treaties between countries by introducing anti-tax avoidance measures. The measures aim at eliminating abuse of bilateral tax treaties, improving dispute resolution, preventing artificial avoidance of permanent establishment status and neutralizing the effects of hybrid mismatch arrangements.
By joining the MLI, Bulgaria fulfills its commitment to create real prerequisites for more effective combating cross-border tax evasion by using offshore accounts and other forms of aggressive tax planning.
We will keep you updated on developments on this topic.