How should staff costs be declared when an employee works under a secondary employment contract (e.g., based on Article 110 of the Labour Code in Bulgaria)?

Under Bulgarian Labour Code, an employee may sign a second labour contract either with the same employer (Art. 110) or with a different employer (Art. 111). According to Article 39 of Regulation (EU) 2021/1059, staff costs consist of the gross employment costs of staff employed by the Interreg partner, which by definition includes all employment costs incurred by the employer for that employee. Therefore, if a beneficiary concludes an additional labour contract under Art. 110, the gross employment costs for that employee must include all contracts with the partner organisation. National instructions for Bulgarian beneficiaries explicitly note that such cases are not treated as full-time employment but as additional duties for the project team. This interpretation is supported by established practice of the national control and confirmed by a Supreme Administrative Court decision (No. 379/31.01.2025).