Bulgaria
определяне на основата по чл. 122 ДОПК — determination of the tax base under Art. 122
Findings at a glance
- Completeness of the data basis
- Requirements for counter-evidence
- Burden of proof and its reversal
2× exceeded · 1× met
Completeness of the data basisexceeded
The revenue authority may apply the statutory rate to a base it determines itself where one of the listed circumstances is present: no return filed, data on concealed income, false or materially incorrect documents, missing or unusable accounts, or a taxpayer who cannot be found.
CitationДанъчно-осигурителен процесуален кодекс (ДОПК), чл. 122 ал. 1
What we provideA full census across all accounts, suppliers and product groups. No sampling is used; 100 per cent is the upper limit and cannot be exceeded by any method.
Requirements for counter-evidenceexceeded
Before applying the provision, the authority notifies the audited person that the base will be determined under Art. 122 and sets a deadline of AT LEAST 14 days to submit evidence and state a position.
CitationДОПК, чл. 124 ал. 1
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 1 axes
Burden of proof and its reversalmet
In appeal proceedings the factual findings of the audit act are deemed CORRECT UNTIL PROVEN OTHERWISE, provided the grounds under Art. 122(1) are supported by the evidence collected.
CitationДОПК, чл. 124 ал. 2
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.