Bulgaria Tax On Vessels Operation Activity : minfin.bg

Organization : Ministry of Finance
Facility : Tax On Vessels Operation Activity
Country : Bulgaria
Website : https://www.minfin.bg/en/771

What is Bulgaria Tax on Vessels Operation Activity?

The taxation on vessels operation is regulated in Articles 254-260 of the Corporate Income Tax Act (CITA). The taxable persons may elect that the vessels operation activity thereof attract a tax on vessels operations activity instead of corporation tax. Under the provision of Article 218(2) of CITA in respect of all other activities those persons shall be liable to corporation tax.

Related / Similar Facility : Bulgaria Tax On Passenger Taxi Transport

Conditions To Avail of the Tax On Vessels Operation Activity

This tax regime can be used by the persons carrying out maritime merchant shipping which simultaneously fulfil the following conditions:
** they are corporations registered under the Commerce Act, or permanent establishments of a corporation which is resident for tax purposes in another Member State of the Economic Union, or a Member State of the European Economic Area, according to the relevant tax legislation and by virtue of a convention for the avoidance of double taxation with a third State is not considered to be resident for tax purposes in another State outside the European Union or the European Economic Area;
** they operate their own vessels or chartered vessels, as well as charter vessels;
** they do not refuse to train apprentices on board the vessels, with the exception of the cases where the number of apprentices exceeds one per fifteen officer members of the ship’s complement;
** they man the vessel with Bulgarian citizens or with nationals of other Member States of the European Union or of the European Economic Area;
** vessels flying the Bulgarian flag or a flag of another Member State of the European Union or of the European Economic Area account for at least 60 per cent of the net tonnage of the vessels operated;
** they carry out the activity thereof in conformity with the requirements of the international conventions and the law of the European Union regarding the safety and security of navigation, protection of the environment from pollution by vessels and the living and working conditions on board the vessel.

This tax regime can be used also by the persons carrying out maritime merchant shipping where the said persons manage vessels on the basis of management agreements and simultaneously meet the following requirements:
** they are corporations registered under the Commerce Act, or permanent establishments of a corporation which is resident for tax purposes in another Member State of the Economic Union, or a Member State of the European Economic Area, according to the relevant tax legislation and by virtue of a convention for the avoidance of double taxation with a third State is not considered to be resident for tax purposes in another State outside the European Union or the European Economic Area;
** vessels flying the Bulgarian flag or a flag of another Member State of the European Union or of the European Economic Area account for at least 60 per cent of the net tonnage of the vessels operated;
** they carry out the activity thereof in conformity with the requirements of the international conventions and the law of the European Union regarding the safety and security of navigation, protection of the environment from pollution by vessels and the living and working conditions on board the vessel;
** more than half of the office on-shore personnel or of the crew is composed of Bulgarian citizens or of nationals of other Member States of the European Union or of the European Economic Area;
** at least two-thirds of the tonnage of the vessels managed is managed by companies which are resident for tax purposes in a Member State of the European Union or in another State which is a Contracting Party to the Agreement on the European Economic Area.

Tax on vessels operation activity shall not be applied to the following vessels:
** any seagoing vessels of a net tonnage under 100 tons;
** any fishing vessels;
** any pleasure vessels, with the exception of passenger vessels;
** any vessels which the taxable persons have provided for management or under a bareboat charter, with the exception of the cases where any such vessels have been provided to the State;
** any rigs for extraction of subsurface resources, any oil production platforms, and any vessels engaged in dredging

Declaring Tax on Vessels Operation Activity

The taxable persons shall submit an annual tax return in a standard form on the tax on vessels operation activity in the period between 01 March and 30 June of the following year. The tax return shall be submitted to the National Revenue Agency territorial directorate exercising competence over the place of registration of the taxable person. An annual activity report shall be submitted together with the annual tax return. Under § 1, point 56 of the CITA Supplementary Provisions annual activity report shall be the report referred to in Article 20 (4) of the Statistics Act.