Capital gains from the sale of shares in a private resident company by non residents are taxed at the rate of 10%. Tax exempt if performed through the stock exchange

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

• Gains from the alienation of immovable property situated in the other State;
• Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State; and

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Tax is withheld at the rate of 5% from gross dividends and liquidation proceeds distributed to non-residents. As of 1 January 2009, dividends paid to companies and other legal entities resident in an EU/EEA country are exempt from withholding taxes pursuant to the Parent-Subsidiary Directive (PSD). However, the exemption does not apply to hidden profit distributions.

10%

Dividend distributions by resident subsidiaries to non-resident EEA parent companies are exempt from any withholding tax.

Tax is withheld at the rate of 10% from gross interest paid to non-residents.

10%

Interest paid by resident subsidiaries to their non-resident EU parent companies or their permanent establishments are subject to a 5% withholding tax between 1 January 2011 and 31 December 2014.

Tax is withheld at the rate of 10% from gross royalties paid to non-residents. As of January 1, 2010, EEA residents may, subject to conditions, opt to calculate the withholding tax due based on the net income realized from Bulgarian sources.

10%

Royalties paid by resident subsidiaries to their non-resident EU parent companies or their permanent establishments are subject to 5% withholding tax between 1 January 2011 and 31 December 2014).

Tax is withheld at the rate of 10% from gross royalties paid to non-residents. As of January 1, 2010, EEA residents may, subject to conditions, opt to calculate the withholding tax due based on the net income realized from Bulgarian sources.

10%

Royalties paid by resident subsidiaries to their non-resident EU parent companies or their permanent establishments are subject to a 5% withholding tax between 1 January 2011 and 31 December 2014.

Tax is withheld at the rate of 10% from gross royalties paid to non-residents. As of January 1, 2010, EEA residents may, subject to conditions, opt to calculate the withholding tax due based on the net income realized from Bulgarian sources.

10%

Royalties paid by resident subsidiaries to their non-resident EU parent companies or their permanent establishments are subject to 5% withholding tax between 1 January 2011 and 31 December 2014.

Tax is withheld at the rate of 10% on payments made by a Bulgarian resident for management services performed outside of Bulgaria by a non resident without a Bulgarian permanent establishment.

Tax is withheld at the rate of 10% on payments made by a Bulgarian resident for technical services performed outside of Bulgaria by a non resident without a Bulgarian permanent establishment.

10%