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Bulgaria and Switzerland Signed Revised Double Taxation Agreement

It replaces the agreement of October 28,  1991 and contains provisions on the exchange of information in accordance with the international standard applicable at present.

On September 19, 2012 Switzerland and Bulgaria signed a new double taxation agreement in the area of taxes on income and capital. 

Aside from an OECD administrative assistance clause, Switzerland and Bulgaria have agreed that both countries may levy withholding tax of no more than 10 % on gross dividend amounts. If, however, a company holds a stake of at least 10 % in the capital of the distributing company for at least a year, the dividends will be exempt from withholding tax. 

Moreover, there will be no withholding taxes on dividends paid to the national banks of the two countries or to pension funds.

Regarding interest, both countries may levy withholding tax not exceeding 5 %. However, interest payments between associated enterprises (stake of 10 % for at least one year), for example, will not be subject to any withholding tax. There will be no withholding tax on royalty payments either. 
 
The new agreement still has to be approved by parliament in both countries before it can come into force.

 
   
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