Bulgaria Bulgarian tax treaties and international conventions Income from real estate in another contracting state from a national territory of a contracting state may be taxed in that other state. Income from a company`s real estate and income from real estate used to provide independent personal services are also covered by this provision. Revenues from direct use, leasing or use in another form of real estate are covered by the agreement. The term “building” refers to real estate within the meaning of the law of the contracting state in which the property is located. It includes variable or fixed payment fees in exchange for variable or fixed payment rights in return for compliance with the activity of mineral and natural resources or the right to work. The control activities of a firm in a contracting state, carried out in another state for more than six months in connection with a construction or construction, installation or assembly project, carried out in that other state, constitute an MOU. Students and interns who resided immediately prior to their visit in a contracting state where he is temporarily present as a student at a recognized university or similar institution or as a recipient of grants, grants or allowances from public, charitable, religious or similar organizations or apprentices in the company are exempt from tax in the other state if they make all deliveries and scholarships from the other state. , as well as any remuneration for services provided for purposes. complement the resources available for its maintenance.

Similarly, a person residing immediately prior to his visit to another State party, if he or she is temporarily staying for up to three years, or the subject of the study, research or training is exempt from tax only as a recipient of a grant, grant or grant from a scientific, educational, religious and charitable organisation or as part of a technical assistance programme concluded by one of the States Parties. Allowances in the other state. Similarly, a resident of one State Party who visits the other State Party for up to twelve months as a worker of the second contracting state or a company with a view to acquiring technical, professional or commercial experience is exempt from the tax collected by the other State Party on the remuneration and transfers received. In the case of a person established in both countries, his or her tax residence is determined by the location of his permanent residence, but if permanent housing is in either country or in neither country, the centre of vital interest is taken into account. If long-term interest rate factors do not determine where you live, a regular stay is considered. and if the person does not have a habitual residence in both countries, nationality is taken into account; And if the person is a national of either country or one of them, the States Parties determine the place of residence by mutual agreement.