DT4163 - DT: Bulgaria: double taxation agreement, Article 14: Salaries and similar remuneration of individuals
- Subject to the provisions of Articles 15, 17 and 18 of this
Convention, salaries, wages and other similar remuneration derived
by a resident of a Contracting State in respect of an employment
shall be taxable only in that State unless the employment is
exercised in the other Contracting State. If the employment is so
exercised, such remuneration as is derived therefrom may be taxed
in that other State.
- Notwithstanding the provisions of paragraph (1) of this
Article, remuneration derived by a resident of a Contracting State
in respect of an employment exercised in the other Contracting
State shall be taxable only in the first- mentioned State if:
- the recipient is present in the other State for a period or
periods not exceeding in the aggregate 183 days in the fiscal year
concerned; and
- the remuneration is paid by, or on behalf of, an employer who
is not a resident of the other State; and
- the remuneration is not borne by a permanent establishment or a
fixed base which the employer has in the other State.
- Notwithstanding the preceding provisions of this Article,
salaries and other similar remuneration derived by a resident of a
Contracting State in respect of an employment exercised or services
rendered in the other Contracting State shall not be taxable in
that other State if the employment is exercised or the services are
rendered directly:
- for a permanent establishment in that other State of an air
transport undertaking or of a National Tourist Office whose place
of effective management is situated in the first-mentioned State;
- aboard a ship, aircraft, railway or road vehicle in
international traffic provided the place of effective management of
the person operating the ship. aircraft, railway or road vehicle is
situated in the first- mentioned State; or
- as a press, radio or television reporter or correspondent and
the remuneration is derived from a source outside that other State.
