However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: a 0 per cent of the gross amount of the dividends if the beneficial owner is a company, which holds directly at least 10 per cent of the capital of the company paying the dividends; or b 5 per cent of the gross amount of the dividends in all other cases. Teie krüptotehinguid saab hõlpsasti teostada, lisades kõik kauplemiseks vajalikud funktsioonid. The law does not precisely define what constitutes fair business transactions. Töödeldud tehingutega, mille summa on üle 21 miljardi dollari, usume, et oleme loonud ühe maailma kõige keerukama Bitcoini turvasüsteemi ja pole kunagi ohtu sattunud. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. Article 4.

Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the State in which the permanent establishment is situated.

Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount.

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In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. Royalties 1.

Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the royalties.

The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein and the Trading System Bulgaaria.

or property in respect of which the royalties are paid is effectively connected with such permanent establishment. Royalties shall be deemed to arise in a Contracting State when the payer is a resident of that State.

Arvustused

Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment with which the right or property on which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right Trading System Bulgaaria.

information for which they are paid, exceeds Trading System Bulgaaria. amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount.

Capital gains 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests deriving more than 30 per cent of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State.

Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, including such gains from the alienation of such a permanent establishment alone or with the whole enterprisemay be taxed in that other State. Gains of an enterprise of a Contracting State operating ships, aircraft, railway or road transport vehicles in international transport from the alienation of ships, aircraft, railway or road transport vehicles or movable property pertaining to the operation of such means of transport, shall be taxable only in that State.

Gains from the alienation of any property other than that referred to in paragraphs 1 to 4, shall be taxable only in the Contracting State of which the alienator is a resident. Income from employment 1. Subject to the provisions of Articles 15, 17, 18, 19 and 20, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State.

If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

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Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Trading System Bulgaaria. State shall be taxable only in the first-mentioned State if: a the recipient is present in the other State for a period or periods not exceeding in the aggregate days in any twelve-month period commencing or ending in the fiscal year concerned, and b the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and c the remuneration is not borne by a permanent establishment, which the employer has in the other State.

Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship, aircraft, railway or road transport vehicle operated in international transport by an enterprise of a Contracting State, may be taxed in that State. Entertainers and sportsmen 1. Notwithstanding the provisions of Articles 7 and 14, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.

Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised.

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  • Persons covered This Convention shall apply to persons who are residents of one or both of the Contracting States.
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The provisions of paragraphs 1 and 2 shall not apply to income, derived from activities exercised by entertainers or sportsmen in a Contracting State where the visit to that State is financed for more than 60 per cent by the other State or a local authority thereof or by an organisation which in that other State is recognised as a charitable organisation. In such case the income shall be taxable only in the Contracting State of which the individual is a resident.

Pensions 1. Pensions and other similar remuneration, paid to a resident of a Contracting State shall be taxable only in that State.

Notwithstanding the provisions of paragraph 1, pensions paid and other similar payments made under a public scheme which is part of the social security system of a Contracting State shall be taxable only in that State. Government service 1. The provisions of Articles 14, 15, 16 shall apply to salaries, wages and other similar remuneration, in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof.

Students and trainees Payments which a student or a trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.

Teachers and researchers 1. An individual who visits one of the Contracting States for the purpose of teaching or carrying out research at a university, college, school or other educational institution recognized by that State, and who immediately before that visit was a resident of the other Contracting State, shall be taxable only in that other State on any remuneration for such teaching or research.

However, this paragraph shall apply only for a period not exceeding two years from the date the individual first visits the first-mentioned State for such purpose. The provisions of this Article shall not apply to income from research if such research is not undertaken in the public interest, but primarily Trading System Bulgaaria.

private benefit of a person. Other income 1.

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Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State. The provisions of paragraph 1 shall not apply to income, other than income from immovable property in respect of which Article 6 is appliedif the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment.

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Elimination of double taxation 1. In Bulgaria Trading System Bulgaaria. taxation shall be eliminated as follows: a Where a resident of Bulgaria derives income which in accordance with the provisions of this Convention may be taxed in Estonia, Bulgaria shall, subject to the provisions of sub-paragraphs b and c of this paragraph, exempt such income from tax; b Where a resident of Bulgaria derives dividends, interest or royalties which in accordance with the provisions of sub-paragraph b of paragraph 2 of Article 10, and the provisions of Articles 11 or 12 of this Convention may be taxed in Estonia, Bulgaria shall allow as a deduction from the tax on the dividends, interest or royalties of that resident an amount equal to the tax paid in Estonia.

Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such dividends, interest or royalties derived from Estonia; c Where in accordance with any provision of this Convention income derived by a resident of Bulgaria is exempt from tax in Bulgaria, Bulgaria may nevertheless, in calculating Interaktiivsete maaklerite voimalus amount of the tax on the remaining income of such resident, take into account the exempted income.

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In the case of a resident of Estonia double taxation shall be avoided as follows: a Where a resident of Estonia derives income which, in accordance with the provisions of this Convention, may be taxed in Bulgaria, Estonia shall, subject to the provisions of sub-paragraphs b and c exempt such income from tax; b Where a resident of Estonia derives income which in accordance with the provisions of: i subparagraph b of paragraph 2 of Article 10; or ii paragraph 2 of Article 11; or iii paragraph 2 of Article 12; or iv paragraphs 1 and 2 of Article 16, may be taxed in Bulgaria, Estonia shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Bulgaria.

Such deduction shall not, however, exceed the part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from Bulgaria; c Where in accordance with any provision of the Convention income derived by a resident of Estonia is exempt from tax in Estonia, Estonia may nevertheless, in calculating the amount of tax on the remaining Trading System Bulgaaria.

of such resident, take into account the exempted income. Non-discrimination 1.

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 Trading System Bulgaaria. requirements to which nationals of that other State in the same circumstances, are or may be subjected.

The taxation on Googl Stock Options 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 enterprise of that other State carrying on the same activities.

The provisions of this Article shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, relieves and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State.

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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 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 which are residents of the first-mentioned State are or may be subjected.

Mutual agreement procedure 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic Trading System Bulgaaria. of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national.

Ettevõtte kirjeldus

The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Convention.

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An agreement shall be reached within a period of two years after the question was formally raised by the competent authority and the agreement shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention.

Aktuaalsed õigusteemad

They may also consult together for the elimination of double taxation in cases not provided for in the Convention. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.

Exchange of information 1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States or their local authorities, insofar as the taxation thereunder is not contrary to the Convention.

The exchange of information is not restricted by Articles 1 and 2. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained Liisingukaubanduse voimaluste liisimine the domestic laws of that State and shall be disclosed only to persons or authorities including courts and administrative bodies concerned with the assessment or collection of, the enforcement or prosecution in respect of, or the Trading System Bulgaaria.

of appeals in relation to the taxes referred to in the first sentence. Such persons or authorities shall use the information only for such purposes.

They may disclose the information in public court proceedings or in judicial decisions. In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: a to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; b to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; c to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy ordre public.

If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes.

The obligation contained in the preceding sentence is subject to the limitations of paragraph 2 but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.

In no case shall the provisions of paragraph Trading System Bulgaaria. be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person.

Members of diplomatic missions and consular posts Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements. Entry into force 1. Your crypto trades can be easily executed, with all the necessary features you need for trading included.

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Nii et kui soovite osta oma esimest Bitcoini või teostate täiuslikku krüptorahaga kauplemise strateegiat, on Luno teie jaoks siin.

Osta Bitcoini ja krüptot hõlpsalt Kui olete krüptoraha kasutuses alles või teil pole lihtsalt aega kauplemisele pühenduda, võtab meie kohese ostmise ja müümise funktsioon krüptokaubanduse keerukuse välja. Salvestage ja teenige oma krüpto eest huvi Luno Trading System Bulgaaria. on nüüd lihtsam kui kunagi varem oma krüptoraha portfelli koostada ja tulevikuks kokku hoida. Intressi makstakse välja igakuiselt.

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Teie kord on teenida, nii et alustage juba täna. Meie BTC ja krüptovahetused on teid kajastanud. Teie krüptotehinguid saab hõlpsasti teostada, lisades kõik kauplemiseks vajalikud funktsioonid. Turvaline oma raha turvaliselt meie krüpto- ja Bitcoini rahakottidega Oleme oma platvormi üles ehitanud nii, et laser keskendub turvalisusele ja kasutajate ohutusele, pakkudes lihtsat ja turvalist viisi oma krüpto salvestamiseks.