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HMRC internal manual

Double Taxation Relief Manual

Bulgaria: Notes


The treaty that entered into force in 2015 replaced that which had been in effect since 1988. Apart from a general updating to reflect changes in the OECD Model Tax Convention and the domestic laws and treaty preferences of both state, notable changes include:


In the 1987 agreement, treaty residence for individuals in the case of Bulgaria was limited to individuals who were nationals of Bulgaria. As a result, a Bulgarian resident who was not also a Bulgarian national was not entitled to any benefits under the treaty, except for a UK national claiming protection in Bulgaria under the non-discrimination article. In the 2015 agreement, the Resident Article is based on the OECD Model and is not linked to nationality.

Associated Enterprises

The 2015 agreement includes, in Article 9, the associated enterprises article that was missing from the 1987 agreement.


The 1987 agreement made provision for visiting teachers to be taxable only in their state of residence in certain circumstances. The 2015 agreement contains no similar provision, but does allow for teachers benefiting from the provision of the 1987 agreement at the time the 2015 agreement enters into force to continue to do so for as long as they would have done under the terms of the 1987 agreement.


The 2015 agreement includes anti-treaty shopping provisions in the dividend, interest, royalty and other income articles.