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Informes Sectoriales OP - Icex

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TOURISM AND RELATED SERVICES IN BULGARIA<br />

above BGN 7,200 BGN 1092 + 24% on the excess over BGN 7,200<br />

(As of 1.1.2006)<br />

4.1.2.3. Withholding Taxes<br />

Certain types of income from sources in Bulgaria and payable to non-resident legal<br />

entities (if not generated through a permanent establishment) or individuals are subject<br />

to withholding taxes. The types of income are defined in CITA as:<br />

♦ dividends and liquidation quotas<br />

♦ interest, including such under finance leases<br />

♦ royalties<br />

♦ technical services remuneration<br />

♦ rents<br />

♦ payments under operating leases, franchising and factoring<br />

♦<br />

♦<br />

remuneration under management contracts<br />

capital gains from transfer of shares in local companies, securities issued by the<br />

State, a municipality or a local entity and local real estate<br />

The withholding tax rate is 7% on dividends and liquidation quotas and 15% on the<br />

other types of taxable income. The withholding tax rate may be reduced under an<br />

applicable double tax treaty.<br />

4.1.2.3.1 Withholding tax exemption for EU citizens<br />

Dividends and liquidation shares, distributed by a local person in favor of a foreign<br />

natural or legal person, local for an EU member-country, are not subject to withholding<br />

tax under the conditions that:<br />

1. According to the tax legislation of the respective EU member-country the person<br />

is considered as local of this country for tax purposes and by force of an<br />

agreement for avoiding the double tax levying with a third state is not considered<br />

as local person of a state out of the EU<br />

2. The person is levied with corporate tax, without having right of choice or exemption<br />

from levying with this tax<br />

3. The person is the actual possessor of the income and holds at least 20% of the<br />

shares/stocks of the local entity<br />

4. By the moment of calculating of the dividends or the liquidation shares the<br />

person has owned the shares/stocks of item 3 continuously for a period not<br />

less than one year.<br />

4.1.2.4. VAT<br />

The Value Added Tax Act (VAT Act) currently in force is effective as from 1 January<br />

1999. Although Bulgaria is not a member of the European Community, the VAT legislation<br />

in many aspects follows the provisions of the Sixth Council Directive<br />

77/388/EEC on the common system of VAT and the uniform basis for its assessment.<br />

The standard VAT rate is 20%. Zero rate of VAT applies to exports of products, certain<br />

eligible exports of services, as well as to some other transactions.<br />

4.1.2.4.1 VAT Registration<br />

Bulgarian and foreign businesses which carry out taxable transactions with a place<br />

of supply in Bulgaria and have a taxable turnover of at least BGN 50,000 during the<br />

preceding twelve months is obliged to register for VAT purposes. Non-residents, ex-<br />

Spanish Economic and Commercial Office of the Spanish Embassy in Sofia 39

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