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13.4.4. APAs and Dispute Resolution Mechanisms


Advanced pricing agreements are not available in Bulgaria. However, a taxpayer can make a request for an opinion from the tax authorities, which is non-binding.


If an adjustment is proposed by the tax authority, the taxpayer has the right to appeal through the same appeals process for other tax adjustments/assessments (Covered Sec. 14.7.).

Dispute Resolution Mechanism

The tax authorities have notified on 10 October 2017 measures for ensuring effective resolution of disputes concerning the interpretation and application of bilateral tax treaties and disputes leading to double taxation. These measures would be applicable to disputes filed from 1 July 2019 in relation to tax years beginning on or after 1 January 2018.