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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 22

Methods for the Elimination of Double Taxation

Double taxation shall be eliminated as follows:

(1) In the case of the Islamic Republic of Iran:

  • (a) Where a resident of the Islamic Republic of Iran derives income which, in accordance with the provisions of this Agreement, may be taxed in Bulgaria, the Islamic Republic of Iran shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Bulgaria.
  • Such deduction shall not, however, exceed that part of the tax as computed before the deduction is given, which is attributable, to the income.
  • (b) Where in accordance with any provision of the Agreement income derived by a resident of the Islamic Republic of Iran is exempted from tax in the Islamic Republic of Iran, the Islamic Republic of Iran may notwithstanding the exemption, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

(2) In the case of Bulgaria:

  • (a) Where a resident of Bulgaria derives income which, in accordance with the provisions of this Agreement, may be taxed in the Islamic Republic of Iran, Bulgaria shall, subject to the provisions of sub-paragraph (b) and (c), exempt such income from tax.
  • (b) Where a resident of Bulgaria derives income which, in accordance with the provisions of Articles 10, 11 and 12 may be taxed in the Islamic Republic of Iran, then Bulgaria shall allow as a deduction from the tax on such income of that resident an amount equal to the tax paid in the Islamic Republic of Iran. Such deduction shall not, however, exceed that part of the Bulgarian tax, as computed before the deduction is given, which is attributable to such income derived from Iran.
  • (c) Where, in accordance with any provisions of this Agreement, income derived by a resident of Bulgaria is exempt from tax in Bulgaria, Bulgaria may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.