24.11.2025
On 20 November 2025, the conference “Transfer Pricing Today: Global Trends, Legislation and Strategic Risk Management” took place in the Aula of Sofia University “St. Kliment Ohridski”.
The event was organized by IFA Bulgaria and the Faculty of Economics and Business Administration of Sofia University “St. Kliment Ohridski”, bringing together business representatives, practitioners, the academic community, and the tax administration to discuss the future of transfer pricing rules in Bulgaria and beyond.
The conference was opened by Assoc. Prof. Dr. Atanas Georgiev, Dean of the Faculty of Economics and Business Administration, and Mr. Valentin Savov, Executive Director of the Bulgarian branch of the International Fiscal Association. Both emphasized that this event creates an important “bridge” – between theory and practice, between the national and international framework, and between business, tax authorities, and academia.
Highlights of the programme:
Ms. Desislava Kaludova, Director of the “Double Taxation Treaties” Directorate at the Central Office of the National Revenue Agency, presented the new Ordinance No. H-3 of 7 November 2025 on the procedures and methods for applying transfer pricing methods, published in State Gazette No. 96 of 11.11.2025. The new ordinance, entering into force on 1 January 2026, harmonizes Bulgarian regulations with the updated OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and reflects recent amendments to the Tax and Social Insurance Procedure Code regarding transfer pricing rules.
Among the speakers was also Prof. Dr. Jacques Malherbe, a long-standing partner and friend of the Faculty of Economics and Business Administration, who congratulated Bulgaria on adopting a legal act in the field of transfer pricing that can serve as a good practice and example for other EU Member States. Prof. Malherbe is a corresponding member of the Royal Academy of Jurisprudence and Legislation of Spain and an honorary doctor of San Marcos University in Lima, Peru. He is an adviser at Simon Brown (Brussels) and a former Vice-Chair of the IFA Permanent Scientific Committee.
Assoc. Prof. Dr. Savina Mihaylova-Goleminova, chair of the Conference Organizing Committee, emphasized that the partnership between IFA Bulgaria, the National Revenue Agency, the Faculty of Economics and Business Administration, and practicing experts is not accidental. This is a model that should be developed further – through training, joint research, and forums like this one. She thanked the entire team working on the organization of the conference, noting that today the Bulgarian professional community proved itself a worthy part of the global communities of the International Fiscal Association (IFA) and the European Association of Tax Law Professors (EATLP).
In closing, it was stressed that transfer pricing is not merely a technique – it is part of the broader discussion about fair taxation, a competitive economy, and trust between the state and business. Bulgaria has taken a confident step forward on its path to OECD membership. The new Bulgarian regulation on methods for determining arm’s length prices updates the national framework and brings it closer to good international OECD practices, which are becoming part of the applicable law in the Republic of Bulgaria. We will no longer speak only of formal compliance with documentation requirements, but of clearer criteria, greater predictability, and better comparability. This is an important step for legal certainty for businesses and for more effective dialogue with the revenue administration. As of 1 January 2026, the OECD Transfer Pricing Guidelines will effectively become “hard law” for Bulgaria and will apply only to future cases.
Other speakers included Dr. Raffaele Petruzzi, Mr. Ivan Neychev, Mr. Ciprian Gavriliu, and Mr. Giammarco Cotani, who delivered valuable lectures and shared extensive practical experience.
The conference was also partnered by Wolters Kluwer Legal & Regulatory, who presented their books in the field of transfer pricing and their Kluwer International Tax Law Platform.
The Organizing Committee expresses its sincere gratitude to the students of the bachelor’s programme “Accounting, Finance and Digital Applications” at the Faculty of Economics and Business Administration for their active participation as volunteers and for their valuable contribution to the successful implementation of the event: Deyan Ivanov; Pamela Petrova; Teodorina Hristova; Radina Bozhinova.
The event was co-financed by the European Union – NextGenerationEU through the National Recovery and Resilience Plan of the Republic of Bulgaria, project No BG-RRP-2.004-0008-C01.