New DTT with Norway

UniCredit Bulbank AD
Summary: 
The text of the new Double Tax Treaty between Bulgaria and Norway was officially published and will be applied as of 1 January 2016
Thu, 17/12/2015

The new DTT between Bulgaria and Norway was published in the State Gazette and provides, among other things, for the following withholding tax rates that shall be applicable for income received after 1 January 2016:

Dividend Income

  • 15%
  • 5%, if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the company paying the dividend income
  • Exemptions applicable to the Central Bank of Norway, the Global Government Pension Fund or other institutions that are owned by Government of Norway by more than 75%, as agreed between the countries.

Interest Income

  • 5%
  • Exemptions applicable:
  • to the Government of Norway, its political subdivision or local authority, the Central Bank Norway or any institution that is wholly owned by the Government of a Norway
  • to loans guaranteed by the Government of Norway, the purpose of which is to encourage exports
  • in connection with the sale on credit of any industrial, commercial or scientific equipment
  • to any loan that is granted by a bank

The DTT also includes provisions on the exchange of information in accordance with international standards.

 

Impact on investors: Eligible residents of Norway can benefit from treaty rates by following the procedure set out in the Bulgarian Tax-Insurance Procedure Code.