• Switzerland - Bulgaria
    Provisions of Tax Treaty Come Into Effect

    21-01-2014

    The provisions of the Income Tax Treaty between Switzerland and Bulgaria came into effect on 1 January 2014.

    In accordance with the new treaty, the following withholding taxes will apply:

    • Dividends:
      • 0% if the beneficial owner of the dividends is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends for a period of at least 1 year prior to the payment of the dividends.
      • 0% if the beneficial owner of the dividends is a pension scheme.
      • 10% in all other cases.

    • Interest:
      • 0% on interest in respect of a debt arising from the sale on credit of equipment, goods or services.
      • 0% on interest in respect of a loan of whatever kind granted by a financial institution.
      • 0% on interest paid by a company to another company if the latter was related to the company paying the interest for a least 1 year prior to the payment of the interest by a direct participation in capital of at least 10% or if the two companies were owned by a third company which held directly at least 10% of the capital of the two companies for at least 1 year prior to the payment of the interest.
      • 5% in all other cases.

    • Royalties: 5% withholding tax on royalties.
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