Tax Law

Governments globally are implementing policies that demand greater financial transparency, while seeking greater tax revenues. Therefore, for the business it is not easy to stay compliant.

We provide skilled and experienced advice to clients at every stage of the tax controversy process, from pre-audit planning to the audit/inspection process and, if necessary, before the courts.

Our tax team is jointly headed by both legal, tax and accounting experts, ensuring together the most appropriate combination of legal, fiscal and financial background.

We represent and successfully defend clients in all phases of tax disputes. In collaboration with our associated tax firm, MKA Finance, we can lead a team of accounting, tax and legal specialist to efficiently and effectively design, implement and defend the tax strategies of our clients.

Our tax specialists possess significant experience in both Bulgarian and international Tax Law matters and advice important local and international entities, institutions and individuals on the taxation and tax planning implication issues arising in the course of their business.

Together with our tax and accounting consultants specialist we can provide a wide range of the following services:

  1. business tax structuring
  2. M&A due diligence and structuring;
  3. tax structures for companies’ reorganisations
  4. corporate and international tax planning involving Bulgarian and foreign entities
  5. litigation
  6. VAT issues in both domestic and international transactions as well as duties and other levies on imported products
  7. Transfer pricing between associated companies
  8. VAT and excise duties
  9. tax assistance on expatriates secondments
  10. customs law, post-clearance recovery of customs duties
  11. tax due diligence and audit
  12. full accounting services, including payroll and financial reporting
  13. representation in front of Bulgarian fiscal authorities and assistance during disputes involving such authorities

Experience shows that the appropriate tax planning of a business transfer may add high value to the transaction irrespective of whether the transaction involves the transfer of assets or shares, a merger, etc.

We at Innovires have expertise within the provision of tax advisory services on both the financing and completion of the transaction itself and also assist after closing with following up on the tax optimisation opportunities and risks that are often identified during the M&A process.

Our network of tax experts outside Bulgaria allows us to include and manage the considerations on foreign direct and indirect taxes that may be relevant to an M&A process involving foreign activities or participants and other stakeholders as part of the transaction.

The skilled tax team also pays important role when it comes to real estate transactions. We provide tax advice on the selection of buyer structure, tax optimisation and purchase of real estate and planning of optimisation in connection with subsequent sales.

We are aware of the VAT challenges related to any purchase, sale and development/construction of real estate and have advised participants in many major projects. 

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25 Vitosha blvd. fl. 2, Sofia, Bulgaria

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Working with clients on their most critical challenges often results in new industry perspectives and insights.

Why Bulgaria

Bulgaria real estate market is pointed as highly dynamic. With an average of 41% growth in sales and 18% rental growth, the luxury property market is dynamically marking the first half of 2017, according to latest statistics. Up to November 2017, the increase in the prices of the properties in the capital – Sofia from the beginning of the year is approximately 14%. Another 10% is expected in 2018.
European Union citizens can now purchase properties in Bulgaria, including land. The 5-year moratorium on land purchases, set as a condition in the Accession Treaty between Republic of Bulgaria and The European Union, was lifted on January 1, 2014. EU citizens and legal person are allowed to buy houses with gardens and regulated plots of land in Bulgaria on their own names. What about non-eu citizens? Foreign individuals from other that EU or EEA countries nationalities, cannot own land (this is a Constitutional prohibition). However, the Foreign Investment Law removed the restrictions on the acquisition of land by locally-registered companies with foreign participation. By setting up or joining a company incorporated under the Bulgarian legislation foreign persons can acquire full land ownership rights including ownership rights on agricultural land. Learn more here.
Bulgaria’s economy expanded by 2.9% in 2017, an improvement from annual growth rates in 2016 and 2015, mainly due to higher net exports and public investment, according to the International Monetary Fund (IMF). The economy is expected to expand by another 3% in 2018, according to the IMF. Bulgaria is in top 3 countries in EU when it comes to economy increase.
Interest rates in Bulgaria continue to decline. The average mortgage interest rate for BGN-denominate loans fell to a record low of 4.3% in 2017, from 6.34% in November 2014, according to the Bulgarian National Bank.
Sofia has moderate to good gross rental yields – i.e., the rental return on a property if fully rented out, before all expenses. Yields in the center were around 6.76% in 2017, up from about 4.7% to 5.7% in the same period last year, based on recent Global Property Guide research. Yields in the suburbs are also moderately good, ranging between 5% and 6.5% over the same period.
Bulgaria has one of the lowest tax burdens in the whole EU and this applies also when it comes to real estate. Real estate annual tax – 0.01%- 0.45% Transfer tax – 0.1%- 3.0% The rate is set by each municipality according to the location of the real estate. The taxable base can be the market price, specifically determined tax value or the gross book value. Keep in mind that there is no tax for agricultural land and forests.