Bulgaria Bulgarian Tax Agreements and International Conventions Permanent establishment The concept of stable settlement is of the utmost importance in terms of taxation under tax treaties. As a general rule, a business that receives income from a country is tax-exempt in that country, unless it has a stable establishment there. Agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation on income and capital taxes The specific provisions for border workers are included in the following double taxation agreements: for example, payments to a UK company that is not subject to a home or taxation in the United Kingdom are not eligible. Similarly, payments made to the bank account of a Hong Kong company are not eligible for the benefits of the Thai tax treaty in Singapore simply because the money is sent to Singapore because that factor alone would not be taxed on the Hong Kong company in Singapore. Tax treaties aim to avoid double taxation and prevent tax evasion. As a general rule, they offer a means of granting a double payment of taxes on the same income to a person who has income that would normally be taxed in more than one country, or a tax credit for the tax paid in one country against the tax debt of a taxpayer in another country. In addition to providing benefits to taxpayers, double taxation agreements also provide for cooperation between governments in the prevention of tax evasion. 1. Where a resident of a contracting state considers that the actions of one or both of the contracting states result in or lead to an imposition that does not comply with the provisions of this Convention, he may, notwithstanding the remedies provided by the national law of those States, submit his case to the competent authority of the contracting state of which he is domiciled. Tax Credits Tax treaties generally provide that the second country generally imposes a tax credit for taxes paid in the first country when the tax is due to more than one country with the same income.
The aim is to avoid double taxation as follows: Thailand first introduced a double taxation agreement in 1963 (with Sweden) and since then it has significantly increased the number of lists. Currently, 55 countries have entered into a mutual double taxation agreement with Thailand: qualifications for the exemption from withholding tax As a general rule, payment must be made to a taxable unit in the recipient country in order for payments to benefit from the exemption from withholding tax. The Double Taxation Convention applies to both individuals and corporations residing in the contracting states. To qualify for contractual benefits, the person must be double taxation if the same reported income is taxed by two or more different legal regimes. This can occur when an individual or business is established or operates in more than one country and is mitigated by double taxation agreements between countries. As a result, income is taxed only once. Tax-exempt income from services and rents on personal property are generally tax-exempt in the country from which they are paid.