(1) Where
a) an enterprise of a Contracting State participates directly or
indirectly in the management, control or capital of an enter-
prise of the other Contracting State, or
b) the same persons participate directly or indirectly in the
management, control or capital of an enterprise of a Con-
tracting State and an enterprise of the other Contracting
State,
and in either case conditions are made or imposed between the
two enterprises in their commercial or financial relations which
differ from those which would be made between independent
enterprises, then any profits which would, but for those condi-
tions, have accrued to one of the enterprises, but, by reason of
those conditions, have not so accrued, may be included in the
profits of that enterprise and taxed accordingly.
(2) Where a Contracting State includes in the profits of an
enterprise of that State – and taxes accordingly – profits on
which an enterprise of the other Contracting State has been
charged to tax in that other State and the profits so included are
profits which would have accrued to the enterprise of the first-
mentioned State if the conditions made between the two enter-
prises had been those which would have been made between
independent enterprises, then that other State shall make an
appropriate adjustment to the amount of the tax charged there-
in on those profits. In determining such adjustment, due regard
shall be had to the other provisions of this Agreement and the
competent authorities of the Contracting States shall if neces-
sary consult each other.
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
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 9 | 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-9/
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