The new requirements for cash registers are another hit on the business environment and, above all, to the “white” business that consciously accounts for and pays taxes. Amendments to the regulation are examples of regulatory instability and the introduction of administrative and financial burdens without an adequate impact assessment.
This was the conclusion of the participants in a press conference held today (22 October 2018), in BIA, where were presented positions, arguments and suggestions of the affected branch and professional organizations in relation to the adopted at the end of September amendments to regulation N-18/2006 on the registration and reporting of sales in retail outlets through fiscal devices. The press conference was attended by Stanislav Popdonchev - Chief Financial Director of the Bulgarian Industrial Association (BIA), Yasen Tanev - founder of the Bulgarian Association for Business Software Development (BABSD), Richard Alibegov - President of the Bulgarian Association of Clubs, and Dr. Nikolay Branzalov - Deputy Chairman of the Bulgarian Medical Association (BMA).
At the beginning of the press conference Stanislav Popdonchev (BIA) stressed that the four organizations support the Ministry of Finance’s efforts to increase fiscal discipline, curb unfair commercial practices and reduce the share of the “grey” economy. “At the same time, the Bulgarian “light” business is seriously concerned about the extremely short deadlines in which it has to comply with the requirements, as well as the unclear wording of the regulation that creates ambiguity, legal uncertainty and economic unpredictability. We have to note that the new requirements in the regulation create additional administrative burdens and require new expenditures that will be significantly higher than the initial estimates,” said the representative of BIA.
He noted that the changes concern practically all traders, including: producers and distributors of specialized software, hotels and other places of accommodation, catering establishments, general practitioners, medical institutions, accounting houses, retailers, courier companies, taxi drivers, craftsmen and liberal professions in the field of trade in goods and services, etc. Even urban transport in some major cities will be affected, indicating that the range of people affected is much wider than originally envisaged.
There are different data about the actual number of functioning fiscal devices, but they are currently at least 250 000. Of these, over 100 000 are not subject to renewal and will need to be replaced. Of the remaining 150 000 devices - about 50 000 are fiscal printers where the upgrading will be more cost-effective than buying a new device, but there will also need to be a replacement for at least 10 000 devices. And another 100 thousand devices that traders will need to choose whether to upgrade or buy new ones. Practice shows that in many cases it is more profitable to purchase a new device instead of updating the existing one.
“It is difficult to calculate the total costs of complying with the requirements of the regulation as there are still too many ambiguities, the cost of new devices and new software, and the cost of retrofitting old devices. But it is almost certain that the “white” business will calculate millions of additional and unforeseen costs. The burden will not be distributed evenly, as the people who use sales management systems in their retail outlets will have to bear even higher costs,” Stanislav Popdonchev noted.
“We are taking action to bring together all branch and professional organizations for a unified position with regard to regulation N-18. We are looking for a dialogue with the Minister of Finance and the National Revenue Agency and we are ready to participate at expert level in any working groups for refining Regulation N-18,” Stanislav Popdonchev (BIA) said. He expressed his readiness in the absence of dialogue to refer the relevant institutions, including the competent court. In addition, there are discriminatory provisions, so the European Commission can be contacted or international investment protection contracts implemented.
