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DT4103 - Double Taxation Relief Manual: Guidance by country: Bulgaria: Notes You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals. Notes The treaty that entered into force in 2015 replaced that which had been in effect since 1988. Apart from a general updating to reflect changes in the OECD Model Tax Convention and the domestic laws and treaty preferences of both state, notable changes include: Residence In the 1987 agreement, treaty residence for individuals in the case of Bulgaria was limited to individuals who were nationals of Bulgaria. As a result, a Bulgarian resident who was not also a Bulgarian national was not entitled to any benefits under the treaty, except for a UK national claiming protection in Bulgaria under the non-discrimination article. In the 2015 agreement, the Resident Article is based on the OECD Model and is not linked to nationality.

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