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The new year will surprise the business with two favorable provisions in the Law on Corporate Income Tax (CIT). Since 2007, interest expense on bank loans or leases ako webmail are secured by assets of the associated company will not be recognized for tax purposes. So far such restrictions in the legal texts relating to the regulation of thin capitalization (unfavorable attracted equity) did not exist. According to tax experts, the new provisions penalizing mostly holdings. Common practice in a holding company assets are concentrated in one company they used as collateral for bank loans taken by another company in the holding company said Valentina Vassileva, tax consultant in "Global Tax". ako webmail She believes that the provision may affect each operating company, as there are no restrictions on the types of collateral in practice, and most banks require aval of promissory notes issued by the business owner. This credit also falls in the case of related parties. According to the European Convention 90/436 / EC on transfer ako webmail pricing transactions between related parties and structures (such as holding companies) should be carried out on a commercial basis. Vasil Velev, Chairman of the Industrial Capital Association, says it's a mistake by not recognizing interest expense on bank loans that are secured by assets of the associated company. "Such loans are granted at market conditions and interest as the lender is a commercial bank and not a related company," stated Velev. According to Valentina Vassileva of the new regulation should be exempted existing operations. Otherwise, the interest ako webmail on loans and longer leases will apply new favorable provisions of the law. Opinion of some representatives ako webmail of the business is that these texts are somewhat offset by the extended deadline for the transfer of unrecognized interest as a result of regulation of thin capitalization from 3 to 5 years. Another favorable change in the ratio of borrowed / equity. To be considered for an enterprise nekapitalizirano this ratio of 2 to 1 is changed to 3 to 1 next year. Another part of the business, however, believes that the use of leverage should be stimulated and not be restricted. In practice, the texts relating to the regulation of thin capitalization are indirect interference of the state in the financial policy of the enterprises. The principal explanation of tax experts is that the thin capitalization regime is designed to avoid the creation ako webmail of companies that are almost entirely ako webmail financed by loans. Companies that finance most of their activities in the form of loans and pay lower taxes because their earnings are reduced by the interest on these loans, as opposed to companies with exactly the same financial results, but financing activities mainly by capital owners. Another provision in the new CITA, which the members of the Confederation of Employers and Industrialists in Bulgaria (CEIBG) would adversely affect the business is related to recognition ako webmail of salary costs in civil contracts. Many companies pay annual bonuses and bonuses to its employees ako webmail last year at the beginning of the next. "By virtue of Art. CITA in 42 if premiums for 2007 and pay effectively in the same year, these amounts will be recognized for tax purposes. A fair will be similar ako webmail costs for the company to be recognized as tax purposes in the year in which the premium was paid, provided that by filing the annual return over the next year, this premium is paid, "said Valentina Vassileva tax consultant. Accountants are concerns that in the awareness ako webmail campaign about the new CIT tax experts give different interpretations which wages are essential and which - extra. For example, ako webmail they state supplements for night work. According Pavlina Kaltcheva, president of the Association of Professional Accounting firms, law texts are in line with European practice. Concerns of the Ministry of Finance is that there is virtually companies charge fees at the end of the year, but are paid after years at lower tax rates for individuals. In other cases, the company accrued expense fees in a year, which reduces the financial result. After
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