From 1 January 2015, payments for the use of, or the right to use, industrial, commercial or scientific equipment will no longer be considered royalties subject to 5% withholding tax as provided for in subparagraph (3)(b) of Article 12 (royalties) of the 2010 Bulgaria-Germany income and capital tax treaty.
Residents of a Contracting State receiving such payments on or after that date from the other State may exempt the income from taxation at source as per Article 7 (business profits), unle…