Taxation

DOBREV & LYUTSKANOV Law Firm has developed great knowledge and wide and in-depth understanding of all taxation matters and tax issues in line with its aim to provide high professional and first class service to our clients in their daily business activities. More specifically, our legal advisors cover all tax aspects related to ongoing transactions, mergers and acquisitions and their tax treatment.

We offer the most optimal alternatives from the viewpoint of taxation. Our advice consists also of tax planning of corporate business activities, such as structuring and restructuring of corporate groups, projects and businesses from the perspective of their tax impact. The lawyers in the firm have big experience in international tax planning, including the enforcement of double taxation agreements. The depth and breadth of our knowledge ensures that we are able to support our clients’ business needs and provide high quality, innovative tax solutions in the increasingly complex area of tax legislation and practice.

Our consultations and legal services in the field of tax law cover, inter alia, the following major areas:

INCOME TAXATION (DIRECT TAXES)

These include both corporate income taxation and the income taxation of individuals.

We advise on corporate re-organisations and restructurings, as well as commercial transactions, including mergers and acquisitions, capital raising, joint ventures, tax efficient holding company and financing structures and permanent establishment issues. Our corporate tax advice relates to the taxation of profit and expenditures, withholding taxes charged on the income from dividends and liquidation quotas, as well as other revenues with their source within the Republic of Bulgaria. The taxation of foreign legal entities for their business operations in Bulgaria, including the issues related to the place of establishment, occupy an important place in our work. We understand the strategic importance of tax to our corporate clients and provide clear, timely and concise advice on all tax related matters. We offer consultation on the personal income taxation, such as the tax on the total annual tax base and the final taxes charged on certain income with its source in the Republic of Bulgaria (e.g. income from dividends, interest rates, rent payments, etc.).

VAT AND OTHER INDIRECT TAXES

DOBREV & LYUTSKANOV Law Firm has indirect tax expertise, in particular value added taxes (VAT), across sectors – from the ever-changing financial sector, through asset finance and corporate, to private client areas. We provide diverse consultations on these matters. They include all types of supplies within the territory of the country, the EU and to/from third countries, such as intra-community supplies and acquisitions, distance selling, triangular operations, imports, exempted supplies and acquisitions, and others. We have been advising and supporting clients in their relationship with local tax authorities, national courts or European legislative bodies. Our consultations in this sphere include other direct taxes, as well, e.g. excise taxes, customs duties, etc.

INTERNATIONAL TAXATION

This area comprises all transactions and structures with an international element, in connection with which the law firm offers advice and legal services. Essential components of the consultations on international taxation and tax planning are the interpretation and application of double taxation agreements or treaties to which the Republic of Bulgaria is a party.

LOCAL TAXES AND FEES

In the course of the implementation of investment projects in Bulgaria, it is inevitable to tackle the issue of the local taxes and fees due, including the real estate tax, the tax charged on the acquisition of properties, the garbage fee, etc. We provide clients with confidential, independent advice for their rights and liabilities. The patent (occupational) tax has become a local tax payable to local government budgets since 1 January 2008.

TAX PROCEDURES

Taxpayers can find themselves in dispute with the tax authorities and in particular there may be disagreement as to the existence or extent of a tax liability. A major element of the activities of DOBREV & LYUTSKANOV Law Firm in the area of tax and financial law is the legal defence and representation of our clients in tax disputes, mainly in the appeal of wrong tax assessments issued by the revenue administration (tax audit statements, netting and recovery acts). We use our knowledge of the tax system as a whole (e.g. VAT and employment taxation), as well as corporate taxation, to give rounded advice. Our services and consultations cover both administrative procedures and court proceedings in tax matters. The law firm has varied and rich practice in tax cases, including refused right to tax deduction, invoking joint liability under the VAT Act for suppliers’ debts, adjustments of the financial results under the Corporate Income Tax Act and others.