Bulgaria: Double tax treaty between Bulgaria and Norway

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: Double tax treaty between Bulgaria and Norway

varbanov.jpg

Petar Varbanov

On July 8 2015, the Bulgarian Parliament ratified the convention for the avoidance of double taxation concluded with the Kingdom of Norway. The convention will apply to persons who are residents of one or both of the contracting states and to any substantially similar taxes that are imposed after the date of signature of the convention in addition to, or in place of, the existing taxes. The existing taxes to which the convention will apply are taxes on income, municipal tax on income, tax relating to submarine petroleum income, pipeline transport of petroleum, national tax on remuneration to non-resident artistes, corporate income tax and patent tax.

Taxation of income

Income derived by a resident of a contracting state from immovable property (including income from agriculture or forestry) situated in the other contracting state may be taxed in that other state. Also, business profits of an enterprise of a contracting state will be taxable only in that state unless the enterprise carries on business in the other contracting state through a permanent establishment (PE) situated therein. Profits of an enterprise of a contracting state from the operation of ships, aircraft, and railway or road transport vehicles in international transport shall be taxable only in that state.

Withholding taxes

According to the convention, dividends shall be taxed with 5% of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends. A tax rate of 15% of the gross amount of the dividends will be applicable in all other cases. Interest arising in a contracting state and paid to a resident of the other contracting state may be taxed in that other state. Such interest may also be taxed in the state in which it arises and according to the laws of that state, but if the beneficial owner of the interest is a resident of the other state, the tax charged will not exceed 5%. Royalty withholding tax charges will not exceed 5% of the gross amount of the royalties paid.

The convention will enter into force on the date of a ratification notification by Norway, which is now pending.

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

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
Gift this article