The Bulgarian Industrial Association (BIA) submitted to the National Assembly its opinions on draft amendments to tax laws, the BIA press office reported on Monday. The parliamentary Budget and Finance Committee is expected to consider the draft legislation at an extraordinary meeting on Tuesday.
BIA supports the proposed amendments to the Excise Duties and Tax Warehouses Act in terms of their objectives of curbing illegal trade in excise goods and improving the effectiveness of controls. However, it insists that the new requirements should be proportionate, clearly regulated and should not impose an unjustified administrative burden on businesses.
The Association broadly supports the proposed amendments to the Value Added Tax Act, but calls for a number of provisions to be further refined to ensure that the digitalization of VAT reporting does not result in additional administrative burdens, technical difficulties or unjustified penalties for businesses.
Regarding the proposed amendments to the Personal Income Tax Act, BIA welcomes the expansion of tax relief for families with children and the introduction of a new tax relief for expenses related to children’s development. At the same time, BIA insists that tax rules should be predictable, known in advance and not dependent on the annual adoption of the state budget.
As regards penalties, BIA maintains its position that Bulgaria’s accession to the eurozone should not be used as a formal pretext for a drastic increase in fines.
BIA does not support the proposed amendments to the Corporate Income Tax Act in their current form and calls for them to be revised. The Association approves of measures to encourage investment and technological upgrading, but objects to proposals that increase the tax burden, restrict the rights of enterprises and create uncertainty for businesses.
BIA supports increasing the maximum monthly value of food vouchers from EUR 102.26 to EUR 200, as well as raising the overall annual quota. However, the Association opposes the introduction of a 7% final tax on food vouchers, including on their value exceeding EUR 102.26.
BIA also objects to increasing the tax rate on in-kind expenses related to the personal use of company assets from 3% to 7%. The Association notes that in 2022 the rate was reduced from 10% to 3% following an assessment of the impact on the budget. Its position paper points out that there is no sufficient analysis to justify an increase of more than twofold.
BIA objects to the approach proposed for certain penalties, under which their numerical amounts would remain unchanged while the word “lev” (the name of the former national currency) would simply be replaced with “euro”. According to the organization, this would result in an approximately twofold real increase in fines and property sanctions, rather than a technical currency conversion.
BIA is firmly opposed to the introduction, in 2027, of an additional 33% tax on certain groups of enterprises, including banks, insurers, telecommunications companies, certain financial institutions, currency exchange offices and some food retailers. The Association insists that the provisions introducing a tax on “excess profits” be withdrawn.
Regarding amendments to the Local Taxes and Fees Act, BIA calls for the mechanism for updating tax assessments to be refined, the impact assessment to be supplemented and the penalties to be converted into euros in real terms. According to BIA, updating the tax bases is necessary because the current values have already diverged substantially from economic reality. However, any increase should take into account differences between settlements and property categories and should not lead to an unjustified rise in the tax burden, the Association argues.
BIA points out that the increase will not automatically affect all enterprises. For non-residential properties, the tax assessment is the higher of the book value and the value determined under the Local Taxes and Fees Act.
Additional costs will arise for enterprises whose new tax assessment exceeds the book value. The changes could also increase transaction costs for commercial properties when the agreed price is below the tax assessment, BIA believes.
BIA supports the compensatory coefficients envisaged for the 2027-2029 period, which prevent an automatic increase in the household waste fee as a result of the new tax assessments.
However, the Association emphasizes that this should not become a permanent solution. BIA’s position is that the household waste fee should be determined according to the amount of waste generated and the services actually provided, in accordance with the “polluter pays” principle.
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