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Changing Your Accountant in Bulgaria — How and When (2026)

Published: June 5, 2026 | Last reviewed: June 5, 2026
Yordan Cholakov June 5, 2026 13 min read

Changing your accountant in Bulgaria is a low-risk operation done right and an expensive mess done wrong. Foreign owners of Bulgarian EOODs and OODs underestimate two things consistently: how much of the documentary trail sits in the prior accountant's hands rather than the company's, and how much personal liability rests on the manager when filings slip through the transition. The Bulgarian Accountancy Act (Закон за счетоводството / ЗС) sets the framework for who is allowed to sign annual financial statements and how long records must be kept; the Tax-Insurance Procedure Code (ДОПК) and the Corporate Income Tax Act (ЗКПО) set the manager's personal liability for failures during the cross-over.

This guide is for the foreign owner of a Bulgarian EOOD who has decided — or is deciding — to switch accountants. We cover the legal frame, the right timing windows in 2026, the document handover list under Article 12 ЗС, the National Revenue Agency electronic-signature revocation procedure, the manager-liability exposure if filings slip, and what to look for in the replacement firm.

1 month
Standard contractual notice for handover
10 years
Retention for accounting registers (Art. 12 ЗС)
50 years
Retention for payroll sheets (Art. 12 ЗС)
EUR 2,556-7,669
Manager fine for general ЗС breach (post-2024)

Why foreign owners of Bulgarian EOODs switch accountants

The trigger is usually one of seven patterns we see repeatedly in new-retainer onboarding. None are isolated complaints — they are structural problems with the prior firm.

  1. No English-language working capability. The foreign owner cannot read the monthly trial balance, cannot follow what is being filed, and depends entirely on translated summaries. For a foreign-owned EOOD this is a non-starter on substance and on POEM/effective-management documentation.
  2. Late filings — even one. A single missed Article 92 ЗКПО return, a missed VAT return under Article 125 ЗДДС, or a missed Declaration 1/6 under Ordinance N-13 triggers fines and, more importantly, opens the door to NRA audit. The pattern usually continues.
  3. No proactive cross-border advice. The accountant does not flag the Article 97a ЗДДС partial VAT registration on the first inbound EU service, does not file VIES correctly, does not coordinate Reg 883/2004 social-security A1 certificates for EU-tied owners, does not advise on the EU 2008/9 refund procedure where Bulgarian VAT is incurred by foreign affiliates. See our Bulgaria VAT refund for foreigners piece for the regime depth.
  4. No proactive tax-planning advice. The accountant does not model salary-vs-dividend mix for the foreign owner, does not flag the 12-tax-period Article 72 ЗДДС input-VAT deadline, does not warn before the EUR 51,130 VAT threshold is crossed. The role becomes purely clerical.
  5. No oborotna vedomost / monthly P&L on schedule. The foreign owner cannot see their own numbers in close to real time.
  6. Per-task add-on fees on top of monthly retainer. Every routine declaration, every NRA letter, every clarification is billed separately. The cumulative cost runs materially above the headline retainer.
  7. Outdated software / no cloud access. The accountant runs an on-premise installation; the foreign owner cannot see the books between monthly closings; data export is partial when the relationship ends.

If any one of these patterns is present and persistent, the case for switching is straightforward. Two or more — switching is overdue.

Recognise two or more patterns? Free 30-minute call — we audit your current setup before you switch.

Three statutory pillars set what the relationship is and what the qualifications need to be.

Article 17 and Article 18 ЗС — who can sign annual financial statements

Article 17 of the Accountancy Act (ЗС) requires that annual financial statements (and interim/consolidated statements) be drawn up by either a natural person in employment or contractual relationship with the enterprise, or by a registered accounting enterprise (счетоводно предприятие). The signer of the statements — the съставител на финансови отчети — must meet the minimum qualifications set in Article 18:

Article 18 ЗС — minimum qualification floor for the signer of AFS
EducationMinimum relevant experience
Master's degree (accounting-economic)2 years
Bachelor's degree (accounting-economic)3 years
Professional bachelor (accounting-economic)4 years
Other higher economic degree5 years
Secondary economic education8 years

Day-to-day bookkeeping — current entries, primary document recording, VAT register maintenance — can be performed by anyone the enterprise designates. The state does not maintain a national licensing register for ordinary accountants in Bulgaria. The Institute of Certified Public Accountants in Bulgaria (ИДЕС) regulates only statutory auditors under the Independent Financial Audit Act, not regular accountants. Practical due diligence on a new accountant therefore means verifying education, experience, software and cross-border literacy directly — the state does not do it for you.

Enterprise categories — which apply to your EOOD

Article 19 ЗС groups enterprises into micro, small, medium and large based on three thresholds (assets, net revenue, employees) measured at 31 December. Converted at the fixed euro adoption rate of 1 EUR = 1.95583 BGN, the post-2024 thresholds are: micro EUR 460,165 assets, EUR 920,329 net revenue, 10 employees; small EUR 5.11m / EUR 10.23m / 50; medium EUR 19.43m / EUR 38.86m / 250. Most foreign-owned EOODs are micro and apply Bulgarian National Accounting Standards (NSS) rather than IFRS, and are not subject to mandatory statutory audit — following the 2024 amendments, small enterprises trigger mandatory audit only when they exceed at least two of: EUR 2,045,165 in assets, EUR 4,090,329 in net revenue, or 50 employees (the asset and revenue thresholds were doubled in 2024 from the legacy BGN 2m / BGN 4m floor).

NRA Universal Electronic Signature (КЕП) — the operational pivot

The accountant typically files through the National Revenue Agency electronic portal (E-portal) using their own Universal Electronic Signature (КЕП / Квалифициран Електронен Подпис) under a written authorisation from the company — see our КЕП for foreign-owned EOODs guide for the issuance and operational practice. The authorisation is granted, modified or withdrawn through service 402 in the IISDA register — the Уведомление за упълномощаване, оттегляне на упълномощаване, промяна на електронен адрес. The revocation is what makes an accountant change real — until it is filed and processed by NRA, the prior accountant retains live access to the company's e-services. We treat КЕП revocation as the first operational step of any switch, not the last.

When to change accountant in Bulgaria — the best switching windows

Switching at the wrong moment turns a routine handover into a missed-filing crisis. Three rules.

Best windows in the 2026 calendar

  1. Start of January. The cleanest cut-over. The prior accountant finishes the December VAT return (filed by 14 January) and Declarations 1 and 6 (filed by 25 January), draws a 31 December trial balance, and hands over. The new accountant takes over the February VAT period and runs the full calendar year. Most disciplined foreign owners we work with switch at year-end.
  2. Mid-May, after Article 50 ЗДДФЛ. The personal income tax filing for self-insured owner-managers and for the foreign owner's own income (filed by 30 April 2026 for 2025 income) is done. The Article 92 ЗКПО corporate return and the 30 June AGM adoption of annual financial statements are six to eight weeks away — enough runway for an onboarding migration audit. Second-best window.
  3. October, after annual financial statements publication. The 30 September 2026 Commercial Register publication of AFS for 2025 is filed. Q4 is operationally lighter than Q2. Acceptable, though less clean than January because mid-year balances mid-flow.

Worst windows — never switch here

The 2026 filing calendar to plan around. Monthly VAT return — 14th of the following month. Declarations 1 and 6 — 25th of the following month. Article 50 ЗДДФЛ personal income tax — 30 April 2026 (for 2025 income). Article 92 ЗКПО corporate tax — 30 June 2026. AGM adoption of annual financial statements — 30 June 2026. Commercial Register publication of annual financial statements — 30 September 2026. SAF-T (large taxpayers only, Phase 1) — 14th of the following month from 14 February 2026. See our Bulgaria tax calendar 2026 for the full annual cadence.

Free engagement-letter teardown — send us your current accountant contract and we mark up the scope gaps.

Accountant handover in Bulgaria — what your old accountant must give you

The single most important sentence in this guide. Company accounting documents are the property of the company. Bulgarian industry practice is consistent: the prior accountant has no lien over them for unpaid fees. An outstanding invoice is a civil-law claim; document retention is not the remedy. The handover must be in full.

Document handover list — Article 12 ЗС storage and the full inventory

Everything below should be transferred, against a приемо-предавателен протокол (handover protocol) signed by the outgoing accountant, the incoming accountant, and the manager:

Article 12 ЗС retention periods — how long records must be kept

Article 12 of the Accountancy Act sets three tiers, counted from 1 January of the year following the reporting period.

Article 12 ЗС — accounting record retention periods
Document typeRetention period
Payroll sheets (ведомости за заплати)50 years
Accounting registers, financial statements, documents subject to tax control, audit or financial inspection10 years
All other accounting information carriers3 years

The 10-year retention for accounting registers aligns with the absolute limitation period for collection of public debts under Article 171 ДОПК (the general 5-year limitation extends to 10 years on an absolute basis). The practical operating rule for foreign owners is to retain the full file for at least 10 years and keep payroll for the full 50 — regardless of what the prior accountant tells you.

If the prior accountant refuses to release records

Rare but it happens. The remedy is a written demand citing Article 12 ЗС and the Article 19 ДОПК manager-liability exposure that the company is being put under. Where the demand is ignored, the next step is a complaint to the Sofia District Court (or the territorial court at the accountant's seat) and a parallel notification to NRA so that the missing-records exposure is documented as caused by the outgoing accountant, not by the company. We have handled this twice in the last twelve months — both times the documents were released after the written demand without litigation.

Manager personal liability if filings slip during the change

The liability sits on the manager — and Bulgarian law treats the manager change moment as a liability transfer point, not a liability reset. Three statutes carry the exposure.

Article 19 ДОПК — personal property liability for tax debts

Where the manager engages in culpable conduct — asset stripping, hidden income, payments to other creditors when taxes were owed, or absence or destruction of accounting documents — the manager is personally liable for the company's unpaid taxes and social-security contributions. NRA can collect against the manager's personal estate. Missing accounting records during a transition is an explicit trigger.

Article 264 ЗКПО — manager fine for late corporate tax return

Personal fine on the manager of EUR 102 to EUR 511 (or EUR 205 to EUR 1,023 on repeat) for failure to file the Article 92 corporate tax return on time. The fine is in addition to the company-level sanction under Article 261 ЗКПО of EUR 256 to EUR 1,534 (EUR 511 to EUR 3,068 on repeat). Amounts shown are the EUR equivalents of the BGN statutory ranges at the fixed conversion rate of 1 EUR = 1.95583 BGN.

Accountancy Act post-2024 fines — materially increased

The 2024 amendments raised general accounting-law sanctions sharply. Manager-level fines for general ЗС violations are now EUR 2,556 to EUR 7,669 (up from EUR 256 to EUR 2,556 pre-2024); enterprise-level fines are now EUR 5,113 to EUR 10,226 (up from EUR 1,023 to EUR 5,113), doubled on repeat. The Commercial Register publication failure for annual financial statements carries a manager fine of EUR 102 to EUR 1,534 (EUR 205 to EUR 3,068 on repeat) and an enterprise fine of 0.1 to 0.5 percent of net revenue, minimum EUR 102.

VAT and VIES penalty exposure during transition

A late VAT return (Article 125 ЗДДС filing obligation) carries a fine under Article 179 ЗДДС of EUR 256 to EUR 5,113. Failure to charge VAT when due is sanctioned at a minimum of EUR 256 or the undeclared tax amount, whichever is higher. Missed VIES filings during a transition between accountants are the single most common refund-and-penalty issue we see in new-retainer onboarding.

The structural risk in plain English. If the prior accountant's last VAT return is not filed, or the first Declaration 1/6 is missed because the КЕП revocation happened before the new accountant onboarded, the manager personally faces BGN-thousands in fines — independent of any contract claim against the prior accountant. The remedy is operational, not legal: schedule the cut-over with both accountants in agreement on who files which return, and never revoke the КЕП until the new accountant's authorisation is live in the NRA portal.

Manager personal liability + missed filings = bad cocktail. Free 30-minute risk-mapping call.

Vetting a new accountant in Bulgaria — the checklist

For a foreign-owned EOOD, the substance of "is this accountant fit" goes far beyond the Article 18 ЗС minimum qualification floor. Six factors decide it.

1. Article 18 ЗС qualification verification

The signer of annual financial statements must meet Article 18. Ask for diploma copies, employment history, and (where applicable) ИДЕС registration. Where the accounting firm is an accounting enterprise, the manager or owner of the firm must meet Article 18 as the signer of statements. Verification is on the client.

2. English-speaking accountant for foreigners — the non-negotiable test

An English-speaking Bulgarian accountant is non-negotiable for a foreign-owned EOOD. We require partner-level English for all client-facing work product — monthly trial balance commentary, VAT-question correspondence, year-end review summaries, NRA-letter translation in real time. Where the accountant communicates only in Bulgarian, the foreign owner has reduced visibility into their own books and reduced POEM/effective-management documentation. The market for English-speaking Bulgarian accountants is meaningfully smaller than the Bulgarian-only market and clusters around Sofia; demand a written work-product sample (a monthly P&L commentary plus one VAT question Q&A) before signing. See our piece on Bulgarian payroll for foreign company owners for what an English-facing monthly deliverable should look like.

3. Professional indemnity insurance — the question most foreign owners skip

Professional indemnity insurance (PII / професионална отговорност) is mandatory only for ИДЕС-registered statutory auditors under the Independent Financial Audit Act. For ordinary accountants and accounting enterprises it is not statutorily required, and uptake across the Bulgarian market is uneven. Ask for the policy and the limit — typical Bulgarian-market PII coverage for an accounting enterprise sits in the EUR 25,565 to EUR 102,258 per-claim range. Without PII, recovery for the accountant's negligence is by civil claim against the firm's own balance sheet — which for a small accounting enterprise is often thin. We carry PII as a default and quote the limits in our engagement letters.

4. Cross-border literacy — the practical test

Ask the candidate accountant five specific questions to test the depth:

The candidate's answers are the test. Hedge answers, "I'll check and get back to you" answers, or wrong answers are disqualifying for a foreign-owned EOOD.

5. The engagement letter — what to demand in writing

Scope (which filings are included, which are extra), monthly retainer, additional-work hourly rate, response SLA (24 to 48 hours business), monthly deliverable schedule (trial balance + commentary by the 20th of the following month), exit and handover clauses (mandatory handover protocol, no document retention for unpaid fees), and an indemnity provision for the accountant's own missed filings. The engagement letter should be bilingual EN/BG; we drag bilingualism into every counterpart agreement we touch.

6. Software stack and cloud access

On-premise stacks (Microinvest, AjurL, ПЛЮС-Минус) versus cloud platforms — for a foreign-owned EOOD, cloud is materially better. The owner can see the trial balance, the VAT register, and the chart of accounts at any time from any geography. Demand it.

7. References from foreign-owned EOODs

Not generic references — references from an EOOD with the same profile (industry, EU clients, foreign owner, single-manager or multi-employee). Ask for three. Call two. The conversation is the test.

Free input-VAT recovery audit — we review your last 12 VAT periods for missed credits before they lapse under Article 72.

Bulgarian accountant fees in 2026 — what it should cost

Indicative monthly retainer ranges for foreign-owned EOODs, in euro from 1 January 2026 onwards.

Bulgaria accountant monthly retainer ranges — 2026
ProfileMonthly retainer
Dormant EOOD (no activity, no employees)EUR 50 – 100
Active EOOD, no VAT registrationEUR 100 – 150
VAT-registered EOOD with EU clientsEUR 150 – 250
Multi-employee EOOD with payrollEUR 200 – 300+
Migration audit on switch (one-off)EUR 300 – 1,500
Annual AFS drafting + Commercial Register publicationEUR 200 – 800 per year

Typically included in the monthly retainer: current bookkeeping, monthly VAT return, Declarations 1 and 6, advance corporate tax instalments, primary payroll, and basic NRA correspondence. Typically extra: annual financial statements drafting and publication, the Article 92 ЗКПО return, statistical reports to the National Statistical Institute, tax-audit defence, retroactive bookkeeping, and the owner's personal Article 50 ЗДДФЛ return. Where the headline retainer is materially below this range, the per-task add-ons are almost certainly making up the difference; demand the engagement-letter scope before agreeing the price.

2026 context — euro opening balances and SAF-T watch

Two specific 2026 issues sit on top of any accountant change this year.

Euro opening balances at 1 January 2026

Bulgaria adopted the euro on 1 January 2026 at the fixed irrevocable conversion rate of 1 EUR = 1.95583 BGN. Bank accounts auto-converted; the general ledger was converted forward only — historical BGN figures were not retrospectively rewritten. Any new accountant onboarding mid-2026 must reconcile the prior accountant's 1 January 2026 opening-balance conversion against the fixed rate. Mismatches typically surface in supplier and customer subsidiary ledgers where multiple-currency balances existed at end-2025. We audit the opening conversion on every new EOOD onboarding this year as a default — see our euro adoption Bulgaria taxes piece for the wider mechanics.

SAF-T context (large taxpayers only in 2026)

SAF-T Phase 1 covers data from 1 January 2026 for the largest enterprises only (2023 net sales above EUR 153.4 million, or NRA payments above EUR 1.79 million — the legacy BGN 300 million / BGN 3.5 million thresholds converted at 1.95583), with the first monthly submission due 14 February 2026. Most foreign-owned EOODs are out of scope through 2028 at the earliest. The new accountant should be aware of the phased rollout and the cross-system data portability implications — see our Bulgaria SAF-T 2026 reporting guide for the phase calendar — but no immediate operational change for the typical foreign-owned EOOD. The longer-runway watch item is the EU-wide ViDA cross-border B2B e-invoicing mandate from 1 July 2030.

Common mistakes foreign owners make when switching

1. Revoking the prior accountant's КЕП before the new one is live

Creates a hole in NRA e-service access. If the timing slips by even a day across a 14th-of-month VAT deadline or a 25th-of-month payroll deadline, the filing is missed. Always grant the new accountant's authorisation first, run a parallel period of one to two weeks, then revoke the prior accountant.

2. Skipping the handover protocol

A signed приемо-предавателен протокол with the trial balance as of the handover date, a complete list of primary documents transferred, and a list of any unrecorded documents creates the audit trail. Without it, the new accountant inherits everything informally and any later dispute is unwinnable. Insist on the protocol.

3. Accepting paper-only handover without software export

Even where Bulgarian accounting software portability is partial, the prior accountant's data export — typically Excel/CSV per ledger and SAF-T XML where supported — is the input the new accountant needs to rebuild the chart of accounts in the new platform. Demand the export in writing.

4. Switching mid-year without a clean trial balance

Where the prior accountant has not closed a recent quarter cleanly, the new accountant rebuilds the books from primary documents — expensive, slow, and error-prone. Where possible, close a clean month-end first (call it the cut-over date), then switch.

5. Not checking the Article 72 ЗДДС 12-period window for input VAT in transit

The single most common refund failure we recover on new retainers. Input VAT not exercised within twelve tax periods of arising is preclusively lost. Audit the prior twelve periods' purchase ledger before the new accountant signs off the cut-over — even where the prior accountant did the work, gaps surface.

Common questions before booking:

Can I change my accountant without telling NRA? Operationally no — until the КЕП authorisation is revoked through NRA's service 402, the prior accountant retains live e-service access. Practical NRA notification happens through the authorisation revocation, not a separate filing.

What if my accountant is also my lawyer's recommendation — is the conflict a problem? Only if the legal and accounting work product begin to overlap (advice on tax-planning vs accounting treatment). For a foreign-owned EOOD, consolidating with a Bulgarian law firm that has accounting partners is usually a net positive — one team, two professions, single point of contact.

Do I have to switch at year-end? No — but it is the cleanest cut-over. Mid-May (after Article 50 ЗДДФЛ) is the second-best window. Anywhere else is workable with care.

What if my prior accountant goes silent during the handover? Written demand citing Article 12 ЗС, parallel notification to NRA, and if needed a Sofia District Court complaint. Manager liability for missing records is invoked against the company, so the urgency is real.

Switch Your Bulgarian Accountant Without Missing a Filing

Tell us your EOOD's current accountant arrangement, your VAT and payroll status, the patterns that prompted the switch, and your preferred cut-over date. We will map the handover sequence, run the prior 12 tax periods' purchase-ledger audit for missed input VAT, file the КЕП revocation and new authorisation, and onboard the new arrangement. Best fit: foreign-owned EOODs with at least 12 months of trading history, EU client invoicing, and approximately 80 to 150 invoices per month or VAT registration. Typical retainer EUR 150 to 250 per month including transition handling. Free initial consultation.

Send Me My Switch Plan →

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Frequently Asked Questions

When is the best time to change an accountant in Bulgaria? +
Start of January (cleanest cut-over after December VAT and Declarations 1/6 are filed), or mid-May after Article 50 ЗДДФЛ filing. Avoid mid-VAT month, days around the 25th payroll deadline, late June (Art. 92 ЗКПО), late September (AFS publication), and any active NRA audit.
What documents must my old accountant hand over? +
Everything that belongs to the company — primary documents, accounting registers, VAT and payroll records, filed declarations, AFS, depreciation schedules, NRA correspondence, originals of powers of attorney, and a software export. Against a signed handover protocol. The accountant cannot retain documents even for unpaid fees.
How long must Bulgarian accounting records be kept? +
Article 12 ЗС: payroll sheets 50 years; accounting registers, financial statements and tax-control documents 10 years; all other accounting information 3 years. The 10-year tier aligns with the Article 171 ДОПК absolute limitation on public-debt collection.
Who is personally liable if filings are missed during the change? +
The manager. Article 264 ЗКПО imposes a EUR 102-511 fine on the manager personally for late corporate tax filing. Article 19 ДОПК extends to personal property liability for unpaid taxes where there is culpable conduct (including absence of accounting documents). Post-2024 ЗС sanctions raised manager-level general-accounting-law fines to EUR 2,556-7,669.
How do I revoke the prior accountant's NRA e-service authorisation? +
Through the NRA E-portal using your own КЕП — service 402 in the IISDA register (Уведомление за упълномощаване, оттегляне на упълномощаване). Either the principal or the accountant can initiate. Effective from NRA processing. We handle the revocation and the new authorisation in one operation.
What qualifications must a Bulgarian accountant have to sign annual financial statements? +
Article 18 ЗС sets the floor: master's degree (accounting-economic) + 2 years, bachelor + 3, professional bachelor + 4, other higher economic + 5, secondary economic + 8 years. No state licensing register for ordinary accountants. ИДЕС regulates only statutory auditors.
What does a Bulgarian accountant cost in 2026? +
Dormant EOOD EUR 50-100/month; active no VAT EUR 100-150; VAT-registered with EU clients EUR 150-250; multi-employee EUR 200-300+. Annual AFS + Commercial Register publication EUR 200-800/year extra. Migration audit on switch EUR 300-1,500 one-off.
Can the prior accountant hold my documents for unpaid fees? +
No. Documents are the company's property. Outstanding fees are a civil-law claim, not a retention basis. If the accountant refuses release, written demand citing Article 12 ЗС, then if necessary a Sofia District Court complaint. We have handled this twice in the last twelve months — both resolved without litigation.
How do I find an English-speaking accountant in Bulgaria? +
The market is meaningfully smaller than the Bulgarian-only market and clusters around Sofia. Demand a written work-product sample (a monthly P&L commentary plus one VAT question Q&A) before signing. Test cross-border literacy through five specific questions (Article 97a, Reg 883/2004 A1, VIES, Article 72 ЗДДС, euro opening balances) covered in our vetting section. For most foreign-owned EOODs the cleanest path is engagement through a Bulgarian law firm with accounting partners — one team, two professions.
Can I do my own accounting for a Bulgarian EOOD? +
Day-to-day bookkeeping yes; signing annual financial statements (the AGFO) only if you personally meet the Article 18 ЗС qualification floor (2 to 8 years of accounting experience by education level). Most foreign owners do not meet the floor and engage an accounting enterprise to sign AFS. The economics also rarely justify DIY at micro-enterprise scale — the time cost exceeds the EUR 100 to 250 monthly retainer.
What is the notice period for terminating a Bulgarian accountant contract? +
No statutory notice. The notice period is whatever the written services contract sets — Bulgarian engagement letters typically use 1 month, though we see anything from 14 days to 90 days. Review the contract's exit clause before serving notice and align the cut-over with the 14th-of-month VAT cycle and the 25th-of-month payroll cycle so no filing is missed.

Sources & Legal References

Primary Bulgarian statutes and EU instruments referenced in this article.

Disclaimer: This article provides general information on changing an accountant for a foreign-owned Bulgarian EOOD as of June 2026. It does not constitute individual legal or tax advice. Penalty ranges, qualification thresholds and filing deadlines may be amended; we update this guide regularly. The Article 12 ЗС retention periods and Article 18 ЗС qualification floor reflect the post-2024 amendments. For a specific case please consult counsel. Last reviewed: June 5, 2026.

Legal notice: This article is for informational purposes only and does not constitute individual legal or tax advice. For your specific situation, please consult a qualified lawyer or tax advisor. The legal framework may change after the publication date.
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