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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Bulgaria: Tax spared

The agreement provides for credit to be given for ‘tax spared’ (see INTM161270) in Bulgaria under the provisions of Bulgarian law set out in Article 22(3), so long as the Bulgarian authorities certify that the Bulgarian tax incentive was given for the purpose of promoting development in Bulgaria.

Matching credit is not to be given for ‘tax spared’ on a source of income arising in a period starting more than ten years after the Bulgarian tax incentive was first granted. Amounts of ‘tax spared’ for which relief is given should be reported as mentioned at INTM161290.