Някои въпроси на данъка при източника по ЗКПО при възмездното разпореждане с български дружествени дялове или акции от страна на чуждестранни юридически лица
Some issues of the withholding tax under CITA upon the disposal for consideration of Bulgarian company shares and stocks by foreign legal entities

Author(s): Tyurker Mollahasan
Subject(s): Law, Constitution, Jurisprudence, Civil Law, Administrative Law
Published by: Университет за национално и световно стопанство (УНСС)
Keywords: withholding taxes; capital gains from disposal of company shares and stocks; foreign legal entities
Summary/Abstract: The report aims to analyze some of the tax consequences that occur in the disposal against consideration of Bulgarian shares or stocks by foreign legal entities. The Corporate Income Tax Act (CITA) is the normative act that regulates these consequences. Moreover, the CITA regulates a different regime depending on the quality of the transferor of the Bulgarian company shares or stocks – whether it is a local legal entity or a foreign legal entity. The report below analysis only the tax implications for foreign legal entities. The essence of the withholding tax under CITA, the object of taxation, the subject of the tax, the specifics of the tax event and the determination of the amount of the tax liability and the rules for declaring and paying the tax are analyzed.

• Details
• Contents