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Bulgaria: Bulgaria – Norway double tax treaty


Rossitza Koleva

A new double tax treaty (DTT) between the Republic of Bulgaria and the Kingdom of Norway was signed in July 2014. The agreement is expected to stimulate the investment climate in the two states and contribute to the implementation of new possibilities and opportunities for companies resident in the two contracting states. Companies will be able to perform activities in the other contracting state in various spheres and sectors.

The main purpose of the treaty is the elimination of double taxation, thus tax paid in one state may be offset against tax payable in the other state, in accordance with the provisions of the treaty and at the same time ensuring that the tax obligations of taxpayers are met.

As such, the effective implementation of the treaty will contribute to the harmonious development of the bilateral economic and investment cooperation between Bulgaria and Norway.

One must take into account the fact that the previous double tax treaty between the two countries was signed back in 1988, in significantly different economic conditions and statutory regulations. The provisions of the newly-signed agreement comply with the OECD's Model Tax Convention, which Bulgaria applies in its contractual practice, as well as with the existing tax laws of Bulgaria and Norway.

This new DTT will be an important tool for the elimination of double taxation for the residents of the contracting countries while at the same time it will ensure the fulfillment of the obligations regarding the payment of the due taxes. The new agreement will enter into force upon its ratification by both sides.

Rossitza Koleva (

Eurofast Global, Sofia Office

Tel: +359 2 988 69 78


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