Bulgaria – Belgium

Dependent Professional Services

Art. 15

1. Subject to the provisions of Art. 16, 18 and 19 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such a remuneration as is derived therefrom may be taxed in that other Contracting State.

2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State, if:

1. the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned;
2. the remuneration is paid by, or is on behalf of, an employer who is not a resident of that other Contracting State; and
3. the remuneration is not borne by a permanent establishment or a fixed base, which the employer has in the other Contracting State.

3. Notwithstanding the preceding provisions of this Art., salaries and other similar remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft in international traffic, or aboard of a boat serving for inland waterways transport are taxable in the Contracting State in which the place of effective management of the enterprise is situated.