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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.


Taxes Covered

(1) This Agreement shall apply to taxes on income and on capital imposed on behalf of a Contracting State, of a land or a political subdivision or local authority thereof, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) in Germany:
    • (i) the income tax (Einkommensteuer);
    • (ii) the corporation tax (Körperschaftsteuer);
    • (iii) the trade tax (Gewerbesteuer); and
    • (iv) the capital tax (Vermögensteuer);
  • including the supplements levied thereon,
  • (hereinafter referred to as "German tax");
  • (b) in Bulgaria:
    • (i) the personal income tax;
    • (ii) the corporate income tax; and
    • (iii) the real property tax;
  • (hereinafter referred to as "Bulgarian tax").

(4) The Agreement shall apply also to any substantially similar taxes that are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their respective taxation laws.