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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 25

Elimination of Double Taxation

(1) In the U.A.E double taxation shall be eliminated as follows:

  • (a) Where a resident of the U.A.E derives income which, in accordance with the provisions of this Convention, may be taxed in Bulgaria, the U.A.E shall allows a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Bulgaria.
  • (b) Such deduction in either case shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in the U.A.E.

(2) In Bulgaria double taxation shall be eliminated as follows:

  • (a) where a resident of Bulgaria derives income which in accordance with the provisions of this Convention may be taxed in the U.A.E, Bulgaria shall subject to the provisions of sub-paragraphs (b) and (c) of this paragraph, exempt such income from tax.
  • (b) where a resident of Bulgaria derives dividends, interest or royalties which in accordance with the provisions of Articles 10, 11 or 12 of this Convention may be taxed in the U.A.E, Bulgaria shall allow as a deduction from the tax on the dividends, interest or royalties of that resident an amount equal to the tax paid in the U.A.E, Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such dividends, interest or royalties derived from the U.A.E.
  • (c) where in accordance with any provision of this Convention income derived by a resident of Bulgaria is exempt from tax in Bulgaria, Bulgaria may nevertheless, in calculating the amount of the tax on the remaining income of such resident, take into account the exempted income.