Bulgaria: Bulgaria and Romania ratify double tax treaty

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Bulgaria: Bulgaria and Romania ratify double tax treaty

varbanov.jpg

Petar Varbanov

Bulgaria and Romania recently ratified a new tax treaty which was signed on April 24 2015. The treaty will replace the one signed in 1995 and extends the existing relief for cross-border dividend, interest and royalty payments. It also introduces stricter anti-avoidance measures and provides for a new mutual assistance procedure for tax collection.

The treaty provides for these withholding tax reliefs:

Dividends

Dividends may be taxed up to 5% of the gross amount paid (the existing treaty provides for a 10% rate on dividends in cases of participations of more than 25% in the distributing entity; 15% rate in all other cases).

No relief will be available in cases of deemed dividend / hidden profit distributions.

Interest

The standard relief under the new treaty is limited to 5% of the interest income (15% provided by the previous treaty). Full relief may be available in cases where the beneficiary is a government authority.

Royalties

The new treaty defines a 5% withholding tax on royalties (previously 15%).

Capital gains

No relief will be available on capital gains tax from alienation of shares in cases where 50% or more of the value of that company's share is derived from real estate.

Irrespective of the treaty however, in specific circumstances, there may be other ways to relieve withholding tax under EU rules and domestic rules of both Romania and Bulgaria.

Permanent establishment

A permanent establishment (PE) will be deemed to be created if a construction site/project exists for a period longer than 12 months. The previous agreement defined a duration of more than nine months as the condition for creation of a PE.

Mutual assistance and anti-avoidance measures

The treaty will facilitate the mutual assistance procedures between the revenue authorities of Bulgaria and Romania. It is expected that the treaty will improve the joint efforts regarding the collection of taxes of all kinds as well as interest, penalties and costs.

Petar Varbanov (petar.varbanov@eurofast.eu)

Eurofast Bulgaria Office

Tel: +359 2 988 69 75

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

ITR’s survey data reveals widespread client disappointment with firms’ use of technology but our upcoming AI in Tax event offers advisers a chance to flip the script
Firms announced key tax partner hires across the US and UK, while fintech and software providers revealed board appointments and new tools for multinational tax teams
It continues a prolific spree of investment for the firm, after it launched in Indonesia, Thailand, Saudi Arabia and Japan in 2025
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
Gift this article