DT4172 - DT: Bulgaria: double taxation agreement, Article 23: Non-discrimination
- Nationals of a Contracting State, as defined in Article 3 of
this Convention, shall not be subjected in the other Contracting
State to any taxation or any requirement connected therewith which
is other or more burdensome than the taxation and connected
requirements to which nationals of that other State in the same
circumstances are or may be subjected.
- The taxation on a permanent establishment which an enterprise
of a Contracting State has in the other Contracting State shall not
be less favourably levied in that other State than the taxation
levied on enterprises of that other State carrying on the same
activities.
- Except where the provisions of paragraph (4) of Article 10 or
paragraph (4) of Article 11 of this Convention apply interest,
royalties and other disbursements paid by an enterprise of a
Contracting State to a resident of the other Contracting State
shall, for the purpose of determining the taxable profits of such
enterprise, be deductible under the same conditions as if they had
been paid to a resident of the first-mentioned State.
- Enterprises of a Contracting State, the capital of which is
wholly or partly owned, directly or indirectly, by one or more
residents of the other Contracting State, shall not be subjected in
the first-mentioned State to any taxation or any requirement
connected therewith which is other or more burdensome than the
taxation and connected requirements to which other similar
enterprises of that first-mentioned State are or may be subjected.
- Nothing contained in this Article shall be construed as
obliging either Contracting State to grant to individuals not
resident in that State any of the personal allowances, reliefs and
reductions for tax purposes which are granted to individuals so
resident.
- In this Article the term `taxation` means the taxes covered by
this Convention.
