Bulgaria: Treaty analysis: Bulgaria and UK sign new double taxation agreement

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Bulgaria: Treaty analysis: Bulgaria and UK sign new double taxation agreement

Varbanov-Petar

Petar Varbanov

On March 26 2015, the Republic of Bulgaria and the United Kingdom of Great Britain and Northern Ireland signed a new Treaty for the Avoidance of Double Taxation (DTT) which will replace the DTT signed in 1987. The new treaty will introduce rules which differ considerably from the provisions now in force.

Scope of taxation

The existing taxes to which the new convention will apply are taxes on interest, royalties and gains from the transfer of shares and interests.

Taxation

Income derived by a resident of one contracting state situated in the other contracting state may be taxed in that other state. If the subject is considered a resident of both states, certain tie-breaker rules apply.

Pursuant to the new DTT, the source country may tax interest income, but if the beneficial owner of the interest is a resident of the other contracting state, such tax shall not exceed 5%. The same rule and withholding tax rate will apply to income from royalties. The new DTT introduces taxation of the gains acquired by a resident of one contracting state from the transfer of shares and comparable interests deriving more than 50% of their value directly or indirectly from immovable property situated in the other contracting state, in that other state (that is, where the property is situated). This rule does not apply to trading of shares on a stock exchange.

Double taxation and tax avoidance

Double taxation in Bulgaria will be eliminated through deducting an amount equal to the amount of tax paid on the respective income in the UK but not through exempting the income from taxation in Bulgaria.

Per the treaty, each of the contracting states will notify the other state of the completion of the procedures required by its law for the bringing into force of the DTT. The new DTT will enter into force on the date of the later of these notifications and will be effective from January 1 of the calendar year following that during which the DTT enters into force.

Petar Varbanov (petar.varbanov@eurofast.eu)

Eurofast

Tel: +359 2 988 69 75

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Boaz Goren’s move to the upstart PE-backed firm takes the number of senior UK tax professionals who have left EY this year to 13
The allegations against Deloitte Cyprus raise uncomfortable questions about how far the big four can distance themselves from misconduct at member firms
The UAE accounted for most Middle East promotions and new rankings, as A&M Tax, Baker McKenzie, Dhruva Consultants and DLA Piper breached the top tier
Spanish-headquartered multinationals lead on reporting quality, while US and Swiss groups lag in the Fair Tax Foundation’s expanded analysis
Former IRS commissioner Danny Werfel joins ITR for a must-listen conversation spanning his time leading the agency, his AI risk framework, and the future of the OECD
Tax and legal services was PwC’s fastest-growing business line last year, helping to put the firm back on a par with its big four rivals
Ex-EY and Hourani & Partners leader Zain Satardien is using flexible staffing and AI-enabled systems to test a leaner model for specialist legal and tax advice
The big four firm is rightfully prioritising transparency and accountability as it seeks to rebuild from its scandal, but a glaring structural issue remains
A recent hiring flurry has taken the firm’s number of partner appointments this year to 121 and put it on track to hit 160 partner target early
The move brings specialist tax and litigation capability to EY as it seeks to close the gap on Baker McKenzie and Venezuela’s leading local firms
Gift this article