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Germany – Bulgaria · Source editionArticle 13 Capital Gains

Unreviewed · applicability unverified

(1)

(1) Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State.

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(2)

(2) Gains derived by a resident of a Contracting State from the alienation of shares or similar rights in a company, resident of the other Contracting State, other than shares quoted on an approved Stock Exchange, may be taxed in that other State.

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(3)

(3) Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Con- tracting State, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise), may be taxed in that other State.

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(4)

(4) Gains of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable prop- erty pertaining to the operation of such ships, aircraft or boats, shall be taxable only in that State.

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(5)

(5) Gains from the alienation of any property other than that referred to in paragraphs 1 to 4, shall be taxable only in the Con- tracting State of which the alienator is a resident.

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(6)

(6) Where an individual was a resident of a Contracting State for a period of five years or more and has become a resident of the other Contracting State, paragraph 5 shall not prevent the first-mentioned State from taxing under its domestic law the capital appreciation of shares in a company resident in the first- mentioned State for the period of residency of that individual in the first-mentioned State. In such case, the appreciation of capital taxed in the first-mentioned State shall not be included in the determination of the subsequent appreciation of capital by the other State.

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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 13 | 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-13/

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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