Bulgaria progressing on SAF-T implementation

• The Standard Audit File for Tax (SAF-T) is an international standard and presents a new means for exchanging information between taxpayers and the administration in Bulgaria.
  
  
• The obligation for preparation and submission of SAF-T is likely to be introduced in phases in Bulgaria, with large taxpayers first.
  
  
• An initial version of the Bulgarian SAF-T has already been published on the National Revenue Agency's website.

The Standard Audit File for Tax (SAF-T), an international standard for electronic exchange of data between taxpayers and tax authorities, is likely to be introduced in phases in Bulgaria depending on the size of the business — affecting large taxpayers first, probably as of 1 January 2025.

The standard, developed by Organisation for Economic Co-operation and Development (OECD), has been introduced in a number of countries. A working version of the XSD scheme of the Bulgarian SAF-T, which follows the OECD structure and has been designed as closely as possible to the OECD scheme, is now available on the official National Revenue Agency website (view here, in Bulgarian only).

Phased implementation

The phased implementation should help provide predictability for the relevant taxpayer group, allowing each group to know when its SAF-T filing obligation arises. The specific timing and starting dates will be set as the drafting process, adoption and enforcement of the regulatory framework unfolds.

Currently, the following phases for implementation, following adoption of the SAF-T legal framework, are being publicly discussed:

• Pilot testing for the first six months, requesting voluntarily filing by large taxpayers
  
  
• Mandatory filing for large enterprises (within the meaning of the Bulgarian Accountancy Act), registered as large taxpayers beginning 12 months after adoption
  
  
• Mandatory filing for all large taxpayers beginning 24 months after adoption
  
  
• Mandatory filing for medium taxpayers beginning 36 months after adoption
  
  
• Mandatory filing for small, medium and large enterprises that are not qualified as large or medium taxpayers beginning 48 months after adoption
  
  
• Mandatory filing for micro-enterprises, registered for value-added tax (VAT) (except for entities that hold a VAT number in Bulgaria by are not established in Bulgaria through a PE or branch), beginning 60 months after adoption

Frequency of reporting

• Monthly: General ledger, purchase and sales invoices, payments
• Yearly: Assets
• At request: Movement of goods

What's coming?

Details related to the scope of the data required for the SAF-T file, mandatory and optional sections and subsections, starting date of the filing obligation, required technical preparation and other key issues will be specified in the regulatory framework to be drafted in the next phase of the reform.

Contact Information

For additional information concerning this Alert, please contact:

Ernst and Young Law Partnership Bulgaria, Sofia

• Milen Raikov
  
  
• Lora Terzieva
  
  
• Tonita Vakarelova

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

For a full listing of contacts and email addresses, please click on the Tax News Update: Global Edition (GTNU) version of this Alert.