Reverse Force for Reverse Hybrid Mismatches in the Bulgarian Tax Law Cover Image
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Обратно действие за обратните несъответствия при хибридни образувания в българското данъчно право
Reverse Force for Reverse Hybrid Mismatches in the Bulgarian Tax Law

Author(s): Stoycho Dulevski
Subject(s): Law, Constitution, Jurisprudence, Law on Economics, EU-Legislation, Administrative Law
Published by: Съюз на юристите в България
Keywords: reverse hybrid mismatches; Council Directive 2017/952; CITA; EU law; substantive tax legal norm

Summary/Abstract: Law on Amendment and Supplementation to the Corporate Income Tax Act (LASCITA) has been promulgated in issue 14 dated 18 February 2022 of the State Gazette. The reverse hybrid mismatches have been introduced in the Bulgarian tax law. This was dictated by the requirements of the secondary EU tax law. It is noteworthy that their entry into force is retroactive for more than a month and a half, namely from 1 January 2022. In this regard, the question arises whether it is an appropriate legislative approach. For the purposes of this paper, attention will be paid both to the theoretical and practical aspects of substantive tax legal norm. Such analysis would be useful by subsequent amendments in the national tax legislation.

  • Issue Year: 2022
  • Issue No: 6
  • Page Range: 68-74
  • Page Count: 6
  • Language: Bulgarian