The Ministry of Finance proposed a project with amendments to Regulation N-18 for obligatory installation of electronic fiscal memories (EFM) with level measuring systems.
The requirements will apply to fixed tanks, both underground or above ground.
Mobile tanks that are used to load fuel for their own needs will have to be equipped with EFM, without the need for level gauges. The project provides requirements, affecting installations for heating and production of which loading will have to be taken into account my means of measurement (flow meter or level gauge), connected with the NRA through a GPRS terminal.
An exception is foreseen for sites with capacities up to 1,000 l which charge no more that 2000 l fuel per year. Deadlines are also defined - for stationary tanks until June 30, 2015; for mobile tanks until September 30, 2015; for heating and production facilities until December 31, 2015.
The project is proposed after a strong lobby by the Bulgarian Petroleum and Gas Association (BPGA), which represents the interests of big chains of petrol stations. Logically, since the burden of departmental sites owned by farmers and transport companies will involve greater costs, it will discourage many of them and will force the owners to refuel from petrol stations - retailers.
The projected requirements will hardly lead to the much desired increase in the collection of indirect taxes and patching the budget holes. Our opinion is that the connection with the NRA through EFM and level gauges will not help to improve the control but will leat to unnecessary costs for the economic entities.
According to the latest amendments to Regulation N-18, departmental sites were obliged to declare a number of circumstances, including size of tanks and fuel consumption. In the current project and the motives behind it, it is not clear how the gathered information influenced the decision to offer ore changes. In addition, it is not clear whether it confirms or refutes the data from the inconclusive analysis of the Ministry of Finance about the huge abuse of departmental sites.
If the aim is to make the departmental petrol stations flawless and safe from a technical point of view, the institutions have a number of mechanisms and applicable regulations to rely on. The government needs to use them and to ensure compliance with the laws of all participants on the market - from tax warehouses, which are a source of hundreds of millions of excise duties and VAT every month, to the smallest consumer of fuel. The projected changes in Regulation N-18, however, will not help with this and will only affect the market in a particular direction.
Stoil Arnaudkin, CEO