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State Gazette, issue 62 /August 6th, 2019
Increased requirements for the activities of private museums provide for changes to the Law on Cultural Heritage. The plan for the museum activity will be accompanied by a plan for the museum building with designated exhibit spaces, storage facilities, sanitary facilities for staff and visitors, workplaces and a laboratory; availability of alarm and security equipment, fire alarm system and fire safety means; draft budget for the maintenance of the building and the staff and funds for activities for the search, study, conservation and presentation of movable cultural values and natural specimens; list of museum positions with the necessary qualification according to the classifier under Art. 37, para. 2. The documents, verifying the requirement for museum exhibits shall be verified ex officio, indicating in the application the name of the museum which carried out the identification of the cultural property and the number and date of the certificate. In case of finding irregularities or incompleteness in the documents, the applicant shall be notified in writing, giving him a period of 10 working days for elimination of the irregularities or incompleteness, stating that, if they are not eliminated, the proceedings will be terminated. The acts of forfeiture of exhibits shall be subject to appeal in accordance with the Administrative Procedure Code.
The subject of the conservation and management plan shall be the activities for the conservation and sustainable development of the immovable cultural value within its boundaries and the protection zone, determined by the statute of granting, in application of the principles of integrated conservation, and at the request of the contracting authority and, if necessary, territories without the status of a protection zone, but in connection with the protected territory for the protection of the intangible cultural heritage, shall be included. Conservation and management plans are developed and implemented in conjunction with the anticipation of the municipal development plans and the spatial plans for the territorial coverage of the single or group real estate values. The assignor of the activities for commissioning of immovable cultural property is obliged to notify in writing the municipality at the location of the site, the Ministry of Culture and the National Institute for Real Estate and Cultural Heritage about the commencement and completion of the implementation - within 10 days after its completion. In case of finding irregularities and incompleteness in the documents, the applicant shall be notified in writing, giving him a period of 10 working days for elimination of the irregularities or incompleteness, stating that their non-elimination will cause termination of the proceedings.
For spatial plans in protected territories for the protection of the immovable cultural heritage and the specific rules and norms thereto, as well as for the tasks for their preparation, coordination or refusal for coordination, shall be performed on the basis of verification of compliance with the requirements of Art. 80. For investment projects and requests for interventions in protected areas for the preservation of the cultural heritage, coordination or refusal of coordination shall be performed on the basis of verification of compliance with the requirements of the ordinance under Art. 171, a co-ordinated planning and design visa or layout scheme and the conservation regimes for the territory concerned. For the plans for the preservation and management of single or group immovable cultural property and the tasks for their preparation, reconciliation or refusal of reconciliation shall be performed on the basis of verification of compliance with the requirements of Art. 81, para. 1, 2 and 3, the ordinance under Art. 81, para. 7 and after the opinion of the Specialized Expert Council under Art. 64, para. 2. Increased control at the side of the Minister of Culture is also envisaged by the changes in the regime of the conservation and restoration of movable cultural property national treasures, as well as the increase of the penal sanctions.

State Gazette, issue 64 /August 13th, 2019
A new chapter in the Code of Insurance Procedure sets out the rules for drawing up documentation to prove that the terms of a commercial and financial relationship between a related party are consistent with the conditions that would be established between independent persons in comparable circumstances, including that transactions were carried out at market prices (”Transfer pricing documentation “). For the purposes of this Chapter, transactions that establish business and financial relationships between related parties (transactions between related parties) are called controlled transactions. Transfer pricing documentation includes a local file and a summary dossier. The local file contains general information on the activities of the person and the owner or owners of the shares or units, as well as details of the transactions controlled and the methods used to determine market prices. The summary dossier contains information on the organizational structure and activities of the multinational enterprise group, the controlled transactions, the functions of the group entities and the applicable transfer pricing policy, such as pricing on related party transactions.
Local legal entities, foreign legal entities that carry on business in the Republic of Bulgaria through a place of business, and sole traders who determine their taxable income in accordance with Art. 26 of the Personal Income Tax Act are obliged to prepare a local file when conducting controlled transactions. The requirement does not apply to persons who are exempt from corporate tax under Part Two, Chapter Twenty Two, Section II of the Corporate Income Tax Act; persons who carry out activity subject to alternative tax under Part Five of the Corporate Income Tax Act; persons who at 31 December of the previous year do not exceed certain indicators for Carrying Oenone assets, net revenues from sales; average number of staff over the reporting period, as well as persons conducting controlled transactions only in the country. A local file is not prepared for controlled transactions with individuals other than sole traders. The local file shall be drawn up by 31 March of the year following the year to which it relates. A corrective annual tax return under Art. 75, para. 3 of the Corporate Income Tax Act, which leads to changes in the data in the local file, it is updated in connection with the correction made. The local file shall be updated within 14 days of the submission of the correction declaration, but no later than 30 September of the current year.
The transfer pricing documentation shall be kept by the obliged persons and shall be made available at the request of the revenue body within the scope of the insurance supervision. The local and summary dossiers are prepared annually. In the absence of significant changes in the comparability factors for controlled transactions, the conducted study of comparable independent transactions and/or persons shall be updated at least every three years. Notwithstanding the first sentence, the financial data of the transactions or persons identified as comparable on the basis of the survey must be updated annually. The provisions shall also apply mutatis mutandis to transfers between a place of business and other parts of the enterprise of a non-resident outside the country. For the purposes of this Chapter, non-personified companies are treated as legal persons.
Rules for the settlement of disputes arising between the Republic of Bulgaria and other Member States (”interested Member States”) concerning the interpretation and application of double taxation treaties or other international treaties of a similar nature have also been settled. Any person concerned has the right to lodge a complaint with the competent authority - the Minister of Finance or an official authorized by him, respectively the administrative court at the permanent address or the seat of the person concerned, to resolve a disputed issue. Where the person concerned does not have a permanent address or head office in the country, disputes shall be considered by the Administrative Court - Sofia. Affected person is any person who is a resident for tax purposes of the Republic of Bulgaria or of another Member State and whose taxation is directly affected by the issue in question. Double taxation within the meaning of this section is the taxation of the same taxable income or property of two or more Member States with taxes which fall within the scope of a treaty or other international treaty of similar nature where this entails additional taxation, increasing tax liabilities or not recognizing any losses that could be deducted from tax profits.