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Germany - Bulgaria Tax Treaty (original 2010 treaty) — Orbitax Tax Hub
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 17

Pensions, Annuities and Similar Payments

(1) Subject to the provisions of paragraph (2) of Article 18, pensions and similar payments or annuities paid to a resident of a Contracting State from the other Contracting State shall be taxable only in the first-mentioned State.

(2) Notwithstanding the provisions of paragraph (1), payments received by an individual being a resident of a Contracting State, from statutory social security schemes of the other Contracting State shall be taxable only in that other State.

(3) Notwithstanding the provisions of paragraph (1), recurrent or non-recurrent payments made by one of the Contracting States or a political subdivision thereof to a person resident in the other Contracting State as compensation for political persecution or for an injury or damage sustained as a result of war (including restitution payments) or of military or civil alternative service or of a crime, vaccination or a similar event shall be taxable only in the first-mentioned State.

(4) The term "annuities" means certain amounts payable periodically at stated times, for life or for a specified or ascertainable period of time, under an obligation to make the payments in return for adequate and full consideration in money or money's worth.

(5) Maintenance payments, including those for children, made by a resident of one Contracting State to a resident of the other Contracting State shall be exempted from tax in that other State. Inasmuch as such maintenance payments are deductible in the first-mentioned State in computing the taxable income of the payer, they may be taxed in that other State. Tax allowances in mitigation of social burdens are not deemed to be deductible for the purposes of this paragraph.