Provisions for Elimination of Double Taxation
Art. 20
The double taxation will be avoided in the following manner:
1. As far as Bulgaria is concerned:
- where a resident of Bulgaria derives income which in accordance with the provisions of this Convention may be taxed in France, Bulgaria shall, in accordance with the provisions of sub-paragraphs and (c), exempt such income from tax;
- where a resident of Bulgaria derives income which, in conformity with the provisions of Art.s 8 or 10 of this Convention, may be taxed in France, Bulgaria shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in France. Such deduction shall not, however, exceed that part of the tax, computed before the deduction is given, which is appropriate to the elements of income derived in France.
- Where, in accordance with any provision of this Convention income derived by a Bulgarian resident is exempted from tax in Bulgaria, Bulgaria may nevertheless, in calculating the tax on the remaining income of that resident, take into consideration the exempted income.
2. As far as France is concerned:
Incomes from Bulgarian sources which are taxed therein in accordance with the provisions of this Convention, are subject to tax if they are derived by a French resident. The tax paid in Bulgaria is not deductable when calculating the taxable income in France.
But the beneficial has the right of tax credit attributable to taxes mentioned in paragraph 1 of Art. 2 of this Convention, in whose base that income is included. The tax credit is equal:
- to the amount of the tax paid in Bulgaria in accordance with the provisions of this convention with respect of income dealt with in Art.s 8 and 10. However, it cannot exceed the amount of the French tax corresponding to that income.
- to the amount of the corresponding French tax for all other incomes.
