According to the present Law on excise duties and tax warehouses for alcohol, used as a cleaning agent in the production of medicinal products, is not considered to have been invested or used in the production process (Art. 22, para. 7), which deprives medicinal producers of the opportunity to recover the excise tax paid on it.
We believe that the existence of such a limitation in the Bulgarian legislation is groundless and unargued from an economic and financial point of view. Regarding goods for human use, excise tax is a tool intended for use against those of them that have a harmful effect on the human body (alcoholic beverages, cigarettes, etc.) and its main purpose is aimed at limiting the use of such types goods. Medicinal products under no circumstances can not to be regarded as dangerous to human health goods, which most accurately explains the need for excise duty exemption (or the possibility of excise duty refund) of all substances used in the process of their production.
In support of our stated thesis, we would also like to note the fact that Directive 2008/118/EC on the general excise duty regime does not provide for preparations (including cleaning alcohol) used in the production of medicinal products to be excised. We hope together with your team to revise the text of Art. 22, paragraph 7 from The law on excise duties and tax warehouses and on behalf of the Ministry of Finance, a proposal for his dropping out. This would not only relieve pharmaceutical manufacturers, who are increasingly burdened with various types of payments to the state, but it would be mostly beneficial for patients, because stable drug prices are important for them, as well as for the country's healthcare system.
Our goal as an employer organization, in which the Bulgarian Generic Pharmaceutical Association (BG PharmA) is a member, as well as a number of pharmaceutical manufacturers, is to work to create more favorable conditions for patients so that they can expand their access to quality, effective, safe and affordable drug therapies.
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