Our full-scope assistance on International Taxation includes:
- Transfer pricing assessment of transactions between associated enterprises and providing feasible solutions to ensure that the arm’s length principle is observed
- Preparing country-specific transfer pricing documentation of local entities
- Advice on constitution of permanent establishment (PE) of non-residents in Bulgaria or local entities abroad and attribution of profits and expenses to the PE
- Withholding tax relief of Bulgarian-source income earned by non-residents (applying for a tax relief provided for in double tax treaties)
- Structuring and planning of international business activities, projects, and supply chains to ensure favorable profit taxation
- Tax advice on cross-border business operations, including assistance in applying methods for elimination of double taxation envisaged in effective double tax treaties
- Supporting local entities to fulfill DAC6 reporting obligations regarding the mandatory automatic exchange of information in the field of taxation on notifiable cross-border arrangements as well as other BEPS measures, where applicable
- Trainings of company personnel focused on specific and/or general international tax matters
- Full-scope assistance in mergers and acquisitions, incl. conduct of tax due diligence procedures