Bulgaria has 71 tax agreements in force, as reported in its response to the Peer Review questionnaire. Two of those agreements, the agreements with Pakistan and Saudi Arabia, comply with the minimum standard.

Bulgaria signed the MLI in 2017 and has not listed its agreements with Finland, Malta and the Netherlands. It indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used for those agreements.

Bulgaria is implementing the minimum standard through the inclusion of the preamble statement and the PPT combined with the LOB.1

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

Bulgaria’s listed agreements under the MLI will start to be compliant after Bulgaria’s ratification of the MLI. Bulgaria indicated that it expected to deposit its instrument of ratification of the MLI early in 2021.


← 1. For 65 of its agreements listed under the MLI, Bulgaria is implementing the preamble statement (Article 6 of the MLI). For its 66 agreements listed under the MLI, Bulgaria is implementing the PPT (Article 7 of the MLI). Bulgaria also opted for the simplified LOB under Article 7(6) of the MLI. Bulgaria made a reservation pursuant to Article 6(4) of the MLI not to apply Article 6(1) of the MLI with respect to agreements, which already contain the relevant preamble language. One of Bulgaria’s agreements, the agreement with Romania, is within the scope of this reservation.

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