Референции за концептуална промяна на мястото на стопанската дейност в българското данъчно право
References For A Conceptual Change Of The Place Of Business In Bulgarian Tax Law

Summary/Abstract: The purpose of this article is to analyze to what extent one of the key concepts in the Bulgarian tax law – the permanent establishment (PE), should be amended both from theoretical and practical perspective. For this purpose, the author will examine the current and more interesting in the recent years relevant practice of the National Revenue Agency (NRA) and the Bulgarian Supreme Administrative Court (SAC). The need for textual change of the concept in the Tax and Social Security Procedure Code (TSSPC) will also be commented. The international initiatives of the Organisation for Economic Co-operation and Development (OECD) how they in uence the national prism will also be taken into account. As a conclusion, recommendations regarding the improvement of the conceptual apparatus will be made. In this regard, the author will pay attention to the possible approaches in clarifying the essence of the PE - symbiosis between theory and practice or predominance of one of them.

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