Amendments to the 15% global minimum tax (Pillar Two) published in the State Gazette

On 27 March 2025 the amendments to the 15% global minimum tax in Bulgaria were officially published in the State Gazette. They concern large Bulgarian groups as well as subsidiaries and permanent establishments / branches of large multinational groups in Bulgaria („the constituent entities“, “CEs”), which group’s annual consolidated revenue was at least EUR 750 million in at least two of the last four fiscal years. The amendments should be applied retrospectively for fiscal periods starting from 1 Jan 2024 or later.

Some of the amendments that in our view would be most relevant in Bulgaria include:

1. The Bulgarian qualifying domestic minimum top-up tax (“QDMTT”) should be calculated based on:

(i) Bulgarian GAAP if the CEs in Bulgaria apply Bulgarian GAAP,

(ii) IFRS if the CEs in Bulgaria apply IFRS,

(iii) The accounting standard in the consolidated accounts (e.g. US GAAP, UK GAAP, etc.) if the CEs in Bulgaria use different accounting standards, e.g. one uses Bulgarian GAAP and the other IFRS.

Under the previous revoked provisions, it was calculated under IFRS and in some cases - Bulgarian GAAP.

2. In scenarios 1(i) and 1(ii) above, the QDMTT should be due for a calendar year. In scenario 1(iii) above, QDMTT should be due for the accounting period of the group, which may or may not coincide with the calendar year. According to the previous revoked provision, QDMTT was due for the accounting period of the group.

Respectively, CEs of groups that follow an accounting year that is different from the calendar year and are in scenarios 1(i) and 1(ii) above need to declare and pay QDMTT for the whole 2024 by 30 June 2026 (under the previous revoked provision: such CEs owed QDMTT for 2024 partially by 18 months from the end of their group’s fiscal period). 

For more information on the amendments see our newsletter.