Article 26 - Non-discrimination - Bulgaria

ARTICLE 26 NON-DISCRIMINATION 1. The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances and under the same conditions are or may be subjected. 2. The term nationals means : (a) All individuals possessing the nationality of a Contracting State; (b) All legal persons, partnerships and associations deriving their status as such from the laws in force in a Contracting State. 3. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities in the same circumstances or under the same conditions. This provision shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which an enterprise of the other Contracting State has in the first-mentioned State at a rate of tax which is higher than that imposed on the profits of a similar enterprise of the first-mentioned Contracting State, nor as being not in accordance with the provisions of paragraph 3 of Article 7 of this Convention. 4. Nothing in this Article shall be construed as obliging a Contracting State to grant to non-residents of that State any personal allowances, reliefs, reductions and deductions for taxation purposes which are by law available only to persons who are so resident. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of that first-mentioned State are or may be subjected in the same circumstances and under the same conditions. 6. In this Article, the term taxation means taxes which are the subject of this Convention.