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

Awards
It was another banner year for Deloitte, which picked up more awards than any other firm at a gala ceremony held at The Londoner in Leicester Square
The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus
Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector
As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands
World Tax data shows Matt Donnelly is moving from a Tier 3 transactional tax practice to a Tier 1 market leader, underlining Kirkland & Ellis’s pull at the top end of the market
Nexdigm's Maulik Doshi and infer360 co-founder Sunil Agarwal dig deeper into their partnership and discuss why the tax technology industry is consolidating
Advisers won’t be short of work in a world of increased valuation disputes, documentation requirements and behavioural responses from clients seeking to protect their wealth
Jaydeep Menon explains how Frazier & Deeter built a specialist practice which helps UK start-ups expand into the US and why private equity backing is accelerating its ambitions
As joint audits, data sharing and pillar two reshape tax controversy, multinational groups can no longer afford to manage disputes one jurisdiction at a time
Brazil's tax system is being reshaped by VAT , pillar two and TP reform. Fallet explains why those changes convinced him to lead a new practice
Gift this article