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Japan Publishes Synthesized Text of Tax Treaty with Bulgaria as Impacted by the BEPS MLI — Orbitax Tax News & Alerts

Japan's Ministry of Finance has published the synthesized text of the 1991 income tax treaty with Bulgaria as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). A summary of the application of the MLI has also been published. The synthesized text has been prepared based on the reservations and notifications (MLI positions) submitted by the respective countries. The authentic legal texts of the tax treaty and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 1991 Japan-Bulgaria tax treaty:

  • in Japan:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
    • with respect to all other taxes levied by that Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 July 2023; and
  • in Bulgaria:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
    • with respect to all other taxes levied by that Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.

Click the following link for the Ministry of Finance's webpage on the BEPS MLI for more information.