EU: CJEU referrals on third-party liability for VAT debts of dissolved company, classification of decorative infused paper sheets under combined nomenclature (Bulgaria)

Requests filed by Bulgarian Supreme Administrative Court for preliminary rulings from CJEU

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September 29, 2025

The Bulgarian Supreme Administrative Court on April 17, 2025, filed a request for a preliminary ruling from the Court of Justice of the European Union (CJEU) (case T-308/25) regarding whether EU law permits a national tax authority to hold a third party liable for unpaid value added tax (VAT) debts of a dissolved company, considering the principles of legal certainty and proportionality under article 273 of the VAT Directive and article 325(1) of the TFEU.

In addition, the Bulgarian Supreme Administrative Court on April 25, 2025, filed a request for a preliminary ruling from the CJEU (case T-304/25) on the tariff classification under the combined nomenclature (CN) for a product composed of paper infused with thermosetting resins used in laminate-coated boards. The court questions whether the product must be classified under CN code 4811 or reclassified under CN code 3921, following laboratory analysis by the Bulgarian customs authority.
 

For further information, please contact a KPMG tax professional in Bulgaria:

Ivan Vargoulev | ivargoulev@kpmg.com

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