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Germany – Bulgaria · Source editionArticle 11 Interest

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(1)

(1) Interest arising in a Contracting State and paid to a resi- dent of the other Contracting State may be taxed in that other State.

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(2)

(2) However, such interest may also be taxed in the Con- tracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the interest.

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(3)

(3) Notwithstanding the provisions of paragraph 2, a) interest arising in Germany and paid in consideration of a loan guaranteed by the Government of Bulgaria, or paid to the Government of Bulgaria, any local authority thereof, or any financial institution, wholly owned by the Government of Bulgaria shall be exempt from German tax; b) interest arising in Bulgaria and paid in consideration of a loan guaranteed by Germany in respect of export or foreign direct investment or paid to the Government of Germany, the Deutsche Bundesbank, the Kreditanstalt für Wiederauf- bau or the Deutsche Investitions- und Entwicklungsge- sellschaft shall be exempt from Bulgarian tax.

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(4)

(4) Notwithstanding the provisions of paragraph 2, interest as referred to in paragraph 1 may be taxed only in the Contract- ing State of which the recipient is a resident if the recipient is the beneficial owner of the interest and the interest is paid a) in connection with the sale of industrial, commercial or scientific equipment on credit, b) in connection with the sale of goods by an enterprise to another enterprise on credit, or c) for a loan of any kind made by a bank.

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(5)

(5) The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mort- gage, and whether or not carrying a right to participate in the debtor’s profits and in particular, income from government securities and income from bonds or debentures, including pre- miums and prizes attaching to such securities, bonds or deben- tures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. However, the term “inter- est” does not include income dealt with in Article 10.

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(6)

(6) The provisions of paragraph 1 to 4 shall not apply if the beneficial owner of the interest, being a resident of a Contract- ing State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein and the debt-claim in respect of which the inter- est is paid is effectively connected with such permanent estab- lishment. In such case the provisions of Article 7 shall apply.

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(7)

(7) Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Con- tracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the State in which the permanent establishment is situated.

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(8)

(8) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

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Source, edition and limits
Source edition
de-bulgaria-2010-base | BGBl. 2010 II S. 1286 | Signed: 2010-01-25 | Gazette publication: 2010-11-23
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Bulgarian as authentic; that third version is NOT present in this reader. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-bulgaria-2010-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2022-07-21; entry into force: 2023-12-13; general application from: 2024-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2010 II S. 1286
SHA-256
6b31dd652c3474a357d75ba5b253c35c4bf30589b7fac5b8ec437b6f4fe5f741

Citation

Copyable citation

BGBl. 2010 II S. 1286 | de-bulgaria-2010-base | de-bulgaria-2010-base | BGBl. 2010 II S. 1286 | Signed: 2010-01-25 | Gazette publication: 2010-11-23 | Article 11 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-bulgaria-2010-base/en/articles/article-11/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 2010 II S. 1286

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

Source-page links are references, not human paragraph verification.

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