In the State Gazette (Държавен вестник), issue 85 of 15 September 2026, an Act Amending and Supplementing the Tax and Social Insurance Procedure Code (Закон за изменение и допълнение на Данъчно-осигурителния процесуален кодекс, ЗИД ДОПК) was promulgated. According to the information published by TITA.BG, the amendments relate mainly to the transposition into Bulgarian legislation of European rules on administrative cooperation in the field of taxation. The main areas include broadening the automatic exchange of information on crypto-assets and electronic money, changes to the scope of the information on financial accounts and income, new rules for exchanging data on the top-up tax for large multinational groups, as well as the refinement of provisions relating to transfer pricing.
Automatic exchange of information on crypto-assets
One of the substantial changes is the introduction of a new section in the Tax and Social Insurance Procedure Code (ДОПК) governing the automatic exchange of information on crypto-assets. A registration regime is established for crypto-asset operators and the obligations of the service providers falling within the scope of the regime are defined.
Reporting providers must identify the tax residence of the relevant users and controlling persons and provide the National Revenue Agency (НАП) with certain identification and transaction information. The data covered concerns operations such as purchases, sales, exchanges, payments and other transfers of crypto-assets. According to TITA.BG's summary, this information is to be provided annually by 30 June of the following year.
Due diligence procedures for crypto-asset users are also laid down. The legislative amendments include administrative penalty provisions for failure to comply with the obligations related to the exchange of information.
Broader scope for financial accounts and electronic money
The amendments also broaden the scope of the automatic exchange of information on financial accounts. It now covers electronic money and central bank digital currencies, while at the same time certain concepts used in the information exchange regime are updated.
Dividends and advance cross-border tax rulings
The range of income for which information may be exchanged is also being widened. Dividends that are not held in a custodial account are added to the existing categories. A related amendment has also been made to the Personal Income Taxes Act (Закон за данъците върху доходите на физическите лица).
The exchange of advance cross-border tax rulings will also cover certain cases concerning individuals. The threshold indicated in the material is above EUR 1,500,000 for the transaction or series of transactions under the respective advance cross-border tax ruling.
Data on the global minimum tax
The Act also governs the automatic exchange between the competent authorities of the data from the information return on the top-up tax for multinational enterprise groups. The rules cover the allocation of the information between the respective jurisdictions and the deadlines for the exchange.
Changes to transfer pricing
In the area of transfer pricing, the definition of "market price" is refined. Alongside the expressly listed methods, the use of another method by the taxable person is allowed under the conditions laid down in the ordinance of the Minister of Finance.
According to the explanatory notes to the bill, as quoted by TITA.BG, the refinement of the definition of market price does not change it in substance. It is noted that the methods for determining market prices are regulated in line with the transfer pricing guidelines.
What the changes mean for business
The practical effect is an increase in the scope and the level of detail of the information that may be collected and exchanged between tax administrations. For the affected enterprises and providers, this raises the importance of data quality, the correct identification of persons, the traceability of operations and timely preparation for the new reporting obligations.
Companies that carry out activities involving crypto-assets, operate within international structures or fall within the scope of the transfer pricing and top-up tax rules should analyse how the amendments specifically apply to their own activities and update their processes and controls where necessary.
Editorial note
This publication is informational and does not constitute individual tax or legal advice.