The Double Taxation Relief (Taxes on Income) (Bulgaria) Order 1987

2. Introductory Text

1. This Order may be cited as the Double Taxation Relief...

3. 2. It is hereby declared — (a) that the arrangements specified...

4. Signature

5. 1. SCHEDULE

      CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE PEOPLE'S REPUBLIC OF BULGARIA FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS

      1. The Government of the United Kingdom of Great Britain and...

      2. Confirming their desire to extend and promote economic co-operation to...

      3. Desiring to conclude a Convention for the avoidance of double...

      4. Have agreed as follows:

      5. ARTICLE 1 Personal scope

         1. This Convention shall apply to persons who are residents of...

      6. ARTICLE 2 Taxes covered

         1. 1. The taxes which are the subject of this Convention are:...

         2. 2. This Convention shall also apply to any identical or substantially...

      7. ARTICLE 3 General definitions

         1. 1. In this Convention, unless the context otherwise requires:

         2. 2. As regards the application of this Convention by a Contracting...

      8. ARTICLE 4 Residence

         1. 1. For the purposes of this Convention, the term “resident of...

         2. 2. (a) Where by reason of the provisions of paragraph (1)...

         3. 3. Where by reason of the provisions of paragraph (1) of...

      9. ARTICLE 5 Permanent establishment

         1. 1. For the purposes of this Convention, the term “permanent establishment”...

         2. 2. The term “permanent establishment” includes especially: (a) a place of...

         3. 3. A building site or construction or installation project constitutes a...

         4. 4. Notwithstanding the preceding provisions of this Article, the term “permanent...

         5. 5. Notwithstanding the provisions of paragraphs (1) and (2) of this...

         6. 6. An enterprise shall not be deemed to have a permanent...

         7. 7. The fact that a company which is a resident of...

      10. ARTICLE 6 Income from immovable property

          1. 1. Income derived by a resident of a Contracting State from...

          2. 2. The term “immovable property” shall have the meaning which it...

          3. 3. The provisions of paragraph (1) of this Article shall apply...

          4. 4. The provisions of paragraphs (1) and (3) of this Article...

      11. ARTICLE 7 Business profits

          1. 1. The profits of an enterprise of a Contracting State shall...

          2. 2. Where an enterprise of a Contracting State carries on business...

          3. 3. In determining the profits of a permanent establishment, there shall...

          4. 4. No profits shall be attributed to a permanent establishment by...

          5. 5. Where profits include items of income which are dealt with...

      12. ARTICLE 8 International traffic

          1. 1. Profits from the operation of ships, aircraft or road vehicles...

          2. 2. If the place of effective management of a shipping enterprise...

          3. 3. The provisions of paragraph (1) of this Article shall also...

      13. ARTICLE 9 Dividends

          1. 1. Dividends derived from a company which is a resident of...

          2. 2. However, such dividends may also be taxed in the Contracting...

          3. 3. The term “dividends” as used in this Article means income...

          4. 4. The provisions of paragraphs (1) and (2) of this Article...

          5. 5. Where a company which is a resident of a Contracting...

      14. ARTICLE 10 Interest

          1. 1. Interest arising in a Contracting State which is derived and...

          2. 2. The term “interest” as used in this Article means income...

          3. 3. The provisions of paragraph (1) of this Article shall not...

          4. 4. Where, by reason of a special relationship between the payer...

      15. ARTICLE 11 Royalties

          1. 1. Royalties arising in a Contracting State which are derived and...

          2. 2. The term “royalties” as used in this Article means payments...

          3. 3. The provisions of paragraph (1) of this Article shall not...

          4. 4. Where, by reason of a special relationship between the payer...

      16. ARTICLE 12 Capital gains

          1. 1. Gains derived by a resident of a Contracting State from...

          2. 2. Gains from the alienation of movable property forming part of...

          3. 3. Gains from the alienation of ships, aircraft or road vehicles...

          4. 4. Gains from the alienation of any property other than that...

      17. ARTICLE 13 Professional services

          1. 1. Income derived by a resident of a Contracting State in...

          2. 2. The term “professional services” includes especially independent scientific, literary, artistic,...

      18. ARTICLE 14 Salaries and similar remuneration of individuals

          1. 1. Subject to the provisions of Articles 15, 17 and 18...

          2. 2. Notwithstanding the provisions of paragraph (1) of this Article, remuneration...

          3. 3. Notwithstanding the preceding provisions of this Article, salaries and other...

      19. ARTICLE 15 Directors' fees

          1. Directors' fees and other similar payment derived by a resident...

      20. ARTICLE 16 Artistes and athletes

          1. 1. Notwithstanding the provisions of Articles 13 and 14 of this...

          2. 2. Where income in respect of personal activities exercised by an...

          3. 3. Notwithstanding the provisions of paragraphs (1) and (2) of this...

      21. ARTICLE 17 Pensions

          1. Subject to the provisions of paragraph (2) of Article 18...

      22. ARTICLE 18 Government service

          1. 1. (a) Remuneration, other than a pension, paid by a Contracting...

          2. 2. (a) Any pension paid by, or out of funds created...

          3. 3. The provisions of Articles 14, 15 and 17 of this...

      23. ARTICLE 19 Students

          1. Payments which a student or business apprentice who is or...

      24. ARTICLE 20 Teachers, etc

          1. 1. An individual who visits one of the Contracting States for...

          2. 2. This Article shall only apply to income from research if...

      25. ARTICLE 21 Income not expressly mentioned

          1. Items of income of a resident of a Contracting State,...

      26. ARTICLE 22 Elimination of double taxation

          1. 1. Subject to the provisions of the law of the United...

          2. 2. In Bulgaria double taxation of income and capital gains shall...

          3. 3. For the purposes of paragraph (1) of this Article, the...

          4. 4. The provisions referred to in paragraph (3)(a) of this Article...

          5. 5. For the purposes of the preceding paragraphs of this Article,...

      27. ARTICLE 23 Non-discrimination

          1. 1. Nationals of a Contracting State, as defined in Article 3...

          2. 2. The taxation on a permanent establishment which an enterprise of...

          3. 3. Except where the provisions of paragraph (4) of Article 10...

          4. 4. Enterprises of a Contracting State, the capital of which is...

          5. 5. Nothing contained in this Article shall be construed as obliging...

          6. 6. In this Article the term “taxation” means the taxes covered...

      28. ARTICLE 24 Mutual agreement procedure

          1. 1. Where a person considers that the actions of one or...

          2. 2. The competent authority shall endeavour, if the objection appears to...

          3. 3. The competent authorities of the Contracting States shall endeavour to...

          4. 4. The competent authorities of the Contracting States may communicate with...

      29. ARTICLE 25 Exchange of information

          1. 1. The competent authorities of the Contracting States shall exchange such...

          2. 2. In no case shall the provisions of paragraph (1) of...

      30. ARTICLE 26 Members of diplomatic and consular missions

          1. 1. Nothing in this Convention shall affect the fiscal privileges of...

          2. 2. Notwithstanding the provisions of paragraph (1) of Article 4 of...

      31. ARTICLE 27 Entry into force

          1. Each of the Contracting States shall notify to the other...

      32. ARTICLE 28 Termination

          1. This Convention shall remain in force until terminated by one...

6. Explanatory Note