Chief Editor
  • Prof. Christina Nikolova, PhD
Editorial Board
  • Prof. Christina Nikolova, PhD - UNWE
  • Prof. Elka Todorova, DSc. - UNWE
  • Prof. Maya Lambovska, DSc. - UNWE
  • Assoc. Prof. Todor Nedev, PhD - UNWE
  • Assoc. Prof. Dorina Kabakchieva, PhD - UNWE
  • Assoc. Prof. Paskal Zhelev, PhD - UNWE
Scientific Secretary
  • Assoc. Prof. Aleksandar Valkov, PhD - UNWE
  • Assist. Prof. Veselina Lyubomirova, PhD - UNWE
International Editorial Board
  • Damian Stantchev, PhD
    Edinburgh NAPIER University, UK

  • Ivaylo Vassilev, PhD
    University of Southampton,UK

  • Prof. Irina Kuzmina-Merlino, PhD
    Transport and Telecommunication Institute, Riga

  • Milan Zdravkovic
    University of Niš, Serbia

  • Prof. Niculae Mihaita, PhD
    Bucharest Academy of Economic Studies, Romania

  • Prof. Ricardo Jardim-Gonçalves, PhD
    UNINOVA institute, New University of Lisbon, Portugal

  • Prof. Ing. Jaroslav Belás, PhD
    Tomas Bata University in Zlín, Czech Republic

  • Prof. John Rijsman, PhD
    Tilburg University

  • Prof. Ing. Zdenek Dvorák, PhD
    University of Zilina, Slovak Republic

  • Prof. Zoran Cekerevac, PhD
    “Union – Nikola Tesla” University in Belgrade, Serbia

Some Issues Regarding the Bulgarian Controlled Foreign Companies' Rules
year 2020
Issue 2

Some Issues Regarding the Bulgarian Controlled Foreign Companies' Rules


The controlled foreign company rules (CFC rules) are a relatively new regime in the Bulgarian domestic legislation. Their introduction in the Corporate Income Tax Act (CITA) is connected with the transposition of Directive 2016/1164. As EU Мember State, Bulgaria is obliged to follow and apply the European law including in the tax law. At the same time, based on the principle of sovereignty, Bulgaria has its own domestic policy.

The CFC rules are a symbiosis of law, economics and accounting. In the Bulgar­ian domestic legislation, they are characterized with numerous challenges both from a theoretical and a practical perspective. Proof of this is their several amendments and the issues concerning their implementation. Due to their new existence and rather con­troversial nature, there are only several articles in the Bulgarian literature that do not explicitly analyze in details this issue.

The main aim of the current study is to outline some of the disputable issues regarding the CFC rules from a Bulgarian perspective. For this purpose, the author makes some recommendations and shares some thoughts regarding the CFC’s future. The applied methods are the historical method, the method of systematic analysis, the formal-logical method and the comparative method.

JEL: K22, K34


EU law, controlled foreign companies, Corporate Income Tax Act, abuse of law, taxation of dividends, taxation of tax profit, Directive 2016/1164, Directive 2011/96
Download Yearbook_2020-2_No05_Dulevski.pdf

ISSN (print): 1312-5486
ISSN (online): 2534-8949