Bg Tax Filing

BG Tax Filing

Ground Rules

• Treat this as high-stakes tax/legal work: verify current-year rules from official NRA/law sources before giving filing instructions.
• Make concrete date assumptions explicit: tax year, filing deadline, and whether dates are past or future.
• Separate facts extracted from documents from legal interpretation.
• Do not optimize for concealment. If the user asks about missed prior years, quantify tax exposure and recommend voluntary correction/consulting NRA or a tax professional.
• Preserve user files. Create new derived workbooks/reports instead of overwriting originals.

Core Workflow

1. Identify the tax year, country of tax residence, platforms, and document paths.
2. Inventory documents with rg --files, then extract structured data:
   • PDFs: try pdftotext; if unavailable use Python pypdf.
   • HTML exports: parse with Python or bundled scripts.
   • XLSX imports: inspect the zipped XML if openpyxl is unavailable.
3. Classify every item into a filing bucket:
   • Rent from Bulgarian real estate: Appendix 4, code 401, with 10% statutory expenses.
   • Foreign shares/ETF holdings at 31 Dec: Appendix 8, Part I.
   • Foreign permanent establishment/base/real estate: Appendix 8, Part II.
   • Foreign dividends/liquidation proceeds: Appendix 8, Part III.
   • Taxable sales of assets/financial instruments and crypto: Appendix 5.
   • Non-taxable regulated-market sales: usually Appendix 13 if reporting them voluntarily/informationally.
   • Crypto only held, with no sale/exchange/spend/staking: normally no appendix.
4. Reconcile holdings:
   • For Appendix 8 Part I, use acquisition date and acquisition cost, not year-end market value.
   • If a position has multiple lots, prefer importing one row per remaining lot/date.
   • For broker summaries, compare computed remaining quantities against year-end positions before producing an import file.
5. Calculate dividends:
   • Convert EUR to BGN at fixed 1.95583.
   • For other currencies, use BNB fixing for the payment date and cite how the rate was obtained.
   • For foreign dividends, default tax is 5% unless an applicable treaty/tax-credit method changes the result.
6. Calculate sales:
   • Use FIFO unless documents or Bulgarian rules require another method.
   • Compute proceeds, acquisition cost, fees when allowed, gain/loss, and tax only on positive taxable gains.
   • For EU/EEA regulated-market securities, verify execution venue before treating gains as non-taxable.
7. Produce a filing pack:
   • Appendix-by-appendix instructions.
   • Tables ready for NRA portal entry.
   • Import-ready XLSX/CSV when the portal accepts imports.
   • A "not filed" list for items intentionally excluded, with rationale.
   • Residual risks and missing documents.

Appendix 8 Practical Notes

• Part I is informational for shares and fund units held abroad as of 31 Dec. It asks for kind, country, count, acquisition date/year, acquisition cost in original currency, and BGN equivalent.
• Use Акции for company shares and Дялове for ETF/UCITS/fund units.
• The country is usually the issuer/fund domicile country from ISIN, not the broker country.
• Part II is only for foreign permanent establishment, fixed base, or foreign real estate. Leave it blank for ordinary broker/crypto holdings.
• Part III code 8141 is for foreign dividends. If no foreign tax was withheld and no double-tax method is applied, method code 3 is usually appropriate; column 12 is 5% of the BGN gross income for that row.

Broker Patterns

• Finax/ETFmatic:
  • Monthly/yearly statements may show holdings and market values, but not full acquisition cost.
  • Use the Transactions page/export for all-time BUY/SELL rows.
  • Run scripts/parse_finax_transactions.py on saved Finax transaction HTML to compute open lots, Appendix 8 Part I rows, dividends, and FIFO realized gains.
• IBKR:
  • Use Activity Statement, Dividend Report, Tax Documents, and Flex Query if many trades exist.
  • Open Positions alone is not enough for Appendix 8 Part I if acquisition cost/date are missing.
• Revolut:
  • Stock P&L reports with zero sells do not prove holdings/dividends.
  • Crypto statements with no transactions/staking usually produce no filing entry.

Bundled Resources

• Read references/bulgaria-nra.md when giving Bulgarian NRA portal instructions, especially Appendix 8 column mapping and risk notes.
• Use scripts/parse_finax_transactions.py for saved Finax transaction HTML exports:

python3 scripts/parse_finax_transactions.py path/to/Transactions.html --tax-year 2025 --out-dir /tmp/bg-tax

The script writes finax-appendix8-part1.csv, finax-open-lots.csv, finax-dividends.csv, finax-realized-sales.csv, and finax-summary.json.