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Update - Amending Protocol to Tax Treaty between Bulgaria and Germany

04 November 2022

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Treaty Development

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Bulgaria-Germany

The amending protocol to the 2010 income and capital tax treaty between Bulgaria and Germany was signed on 21 July 2022. The protocol is the first to amend the treaty and includes the following changes: The Title and Preamble are updated in line with OECD BEPS standards; Article 3 (General Definitions) is updated in regard to the definition of the term "Germany"; Article 22 (Elimination of Double Taxation) is updated in regard to Bulgaria, which applies the credit method in general (previously applied the exemption method in general, with a credit for dividend, interest, royalties, and certain capital gains); Article...