Mutual Agreement Procedures (MAP)

MAP is an effective mechanism for resolving international tax disputes between Bulgaria and countries with which it has a valid Double Taxation Treaty (DTT).

In essence, MAP allows the taxpayer to initiate a process of communication between the Bulgarian National Revenue Agency (NRA) and the relevant foreign tax authority to ensure that tax adjustments are recognized consistently in both jurisdictions. For example, if a transfer pricing adjustment leads to an upward income correction in Bulgaria, one of the key objectives of MAP is to secure a corresponding downward adjustment in the other country. Unlike formal appeals, MAP carries no adverse outcome for the taxpayer once the authorities reach an agreement.