Bulgaria: New income tax treaty with Romania | KPMG | GLOBAL
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Bulgaria: New income tax treaty with Romania

Bulgaria: New income tax treaty with Romania

A new income tax treaty between Bulgaria and Romania has been ratified and entered into force, and the treaty provisions generally will be effective beginning 1 January 2017.


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The new income tax treaty replaces the existing treaty (1994) and includes measures that differ from the provisions under the existing treaty concerning:

  • Tax residency rules
  • Permanent establishments include building sites, project construction, and assembly or installation project
  • Withholding tax rates of 5% on interest and royalties
  • Taxation of capital gains


Read a September 2016 report [PDF 223 KB] prepared by the KPMG member firm in Bulgaria: New Double Tax Treaty between Bulgaria and Romania

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