Amending Protocol to Tax Treaty between Bulgaria and Germany has Entered into Force

The amending protocol to the 2010 income and capital tax treaty between Bulgaria and Germany entered into force on 13 December 2023. The protocol, signed 21 July 2022, is the first to amend the treaty and includes the following changes:

• The Title and Preamble are updated in line with OECD BEPS standards;
• Article 3 (General Definitions) is updated in regard to the definition of the term "Germany";
• Article 22 (Elimination of Double Taxation) is updated in regard to Bulgaria, which applies the …