In connection with the draft Law on the State Social Security Budget for 2014 provided to us, on behalf of the Confederation of Employers and Industrialists in Bulgaria, we express the following position:
1. In Article 8, Paragraph 1, Item 4, the figure 2400 BGN should be replaced by 2200 BGN.
Motive:
Such growth will increase the cost of social and health insurance and negatively affect both employers and employees, as it will increase the costs of legitimate business and reduce the net income of high-paid workers. This will greatly affect those employed in IT sector and will lead to the closure of operating companies or their relocation to neighboring countries with a more favorable regime. At the same time, it is not clear the effect of such an increase in the maximum insurance income and whether it will lead to the desired increase in income in the funds of the National Social Insurance Institution. Once again, an attempt is made to shore up the insurance system by shifting the burden to those who are in the light. Instead of solving the problems of the pension model through adequate measures, an increase in the maximum pension is again undertaken by increasing the maximum insurance income.
2. In the transitional and final provisions § 4 to drop.
Motive:
Once again with the norms provided in §4 of the Transitional and final provisions of the draft law, restrictions are introduced for the persons who can carry out prevention and rehabilitation activities. In this regard, we insist on reconsidering the possibility of admission to participation in the procedure for the selection of contractors for the prevention and rehabilitation of NOI of hotels carrying out rehabilitation and prevention activities in balneo and spa centers built to the complexes and having the relevant medical staff, modern building stock and medical equipment.
With the dropping of §4, the activity will be given the opportunity to be carried out according to the general procedure - with a competition, as provided for in art. 13c, para. 4 of the Social Insurance Code.
3. In Annex No. 1 to Art. 8, Para. 1, Item 1 – Minimum insurance income by main economic activities and qualification groups of professions for 2014: for ik. activities in which MoD agreements have been reached by categories of professions to be reflected in their agreed amount; for the activities without reached agreements, the MOD should be determined while maintaining the level reached in 2013. The amount of the MRL should be kept at the level reached in 2013.
Motive:
Issues related to labor and insurance relations are an element of the consultations with the social partners. The social partners were not consulted about the amount of the MFZ. In times of crisis, the increase in the national income tax is not justified. Such an increase must be tied to labor productivity and labor costs. The administrative determination of the amount of social security that the business pays will lead to a new release of labor, and above all to the lowest qualified. Given that smaller firms are already staffed at the limits of their efficiency, the likelihood of them turning to the gray sector is real.
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