Bulgaria

Transfer Pricing in Bulgaria

Bulgarian transfer pricing (трансферно ценообразуване) for tax year 2026 under the Corporate Income Tax Act (ZKPO) Article 15, the Tax-Insurance Procedure Code (DOPK) Chapter 8a (Articles 71a to 71zh), Articles 116 and 278a, the related-party definition in DOPK Additional Provisions para. 1 item 3, and Ordinance N-3 of 7 November 2025 on the market price methods, which replaced Ordinance N-9 from 1 January 2026. Covers who is related, the arm's length rule for domestic and cross-border deals, the five methods, the interquartile range and adjustment to the median, local and master file tests and euro thresholds, the 30 June deadline, hidden profit distribution, penalties, country-by-country reporting and the absence of an APA procedure.