Transfer pricing

Transfer pricing

Globally, countries tax their local tax on profits for products, services and rights produced on their territory. For their part, groups of companies operating in different countries seek to minimize the tax on their profits, in order to obtain more favorable tax conditions for their activities. That is why they are targeting countries with lower corporate taxes.

This leads to the adoption of general principles and rules aimed at fair transnational pricing, etc. transfer pricing. It aims at a fair tax on the margin for products, services and rights produced in the territory concerned.

What we can offer you

Transfer pricing determines these price levels for the purchase and sale of goods, services and rights between related parties, as they would be if the transactions were concluded between unrelated parties in a free and competitive market.

As part of the international consulting network TIAG ALLIENCES, we have the necessary competence, methodology and databases with which we can determine the market margins at which related parties in Bulgaria and abroad to trade products, services or rights.

The TSSPC sets out all the rules for transfer pricing, and it should be borne in mind that any deviation from them is associated with significant revision acts.

Among the statutory sanctions are:

– A person who does not prepare a local file under Chapter Eight “a” shall be punished with a pecuniary sanction of up to 0.5 percent of the total value of the transactions for which the documentation should have been prepared. When granting or receiving a loan, the total value of the transaction is considered to be its amount. It is assumed that the local dossier has not been prepared when it has not been submitted at the request of a revenue authority within the time limit set by it.

– A person who does not have a summary file under Art. 71d, when obliged to do so, shall be punished by a pecuniary sanction in the amount of BGN 5,000 to 10,000.

– A person who indicated incorrect or incomplete data in the transfer pricing documentation under Chapter Eight “a” shall be punished with a property sanction in the amount of BGN 1,500 to BGN 5,000.

– In case of repeated violation under para. 5 – 7 a property sanction in double amount is imposed.

Therefore, we at Brain Storm Consult are ready to offer you adequate and professional service to protect the interests of our clients who are part of a group and trade with related parties abroad. We prepare internationally standardized and reasoned reports proving that all transactions between related parties in their various jurisdictions comply with transfer pricing rules.

Trust our experience and professionalism. For more information you can use the form “Make an inquiry” or write to us at or contact us at +359 2 80 99 740.


  • 1729 Sofia 1A “Mladost”, building 505A, entry 2.
  • +359 2 80-99-740

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