BulgariaThe Bulgarian tax treaty and international conventions Unless expressly excluded from a contract, income from foreign sources is taxable in France. Residents are entitled to WHT tax credits for certain types of income from other countries in the tax treaty. However, income from foreign sources exempt from French tax under a tax treaty is added to taxable income in France, either to determine the French tax rate on taxable income (exempt with progression), or to calculate France`s gross tax debt from which taxes paid abroad (tax credit system) are deducted, according to current tax legislation. A. For the purpose of determining the profits of a stable establishment, the deduction may be made at second-place expenses, including administrative expenses incurred in the contracting state where the establishment is located or in another location, in accordance with the provisions and subject to the limitations of the tax legislation of that contracting state. Where the law of the State party in which the establishment is established imposes a limitation on the level of authorized administrative expenses of the executive and general administrative expenses and the restriction is relaxed or repealed by a convention, agreement or protocol signed after 1 January 1990 between that State party and a third member state of the OECD, and that limitation is applied by a convention signed after 1 January 1990 , the agreement or protocol between that contracting state and a third oecd member state will be relaxed or repealed. The competent authority of that contracting State communicates to the competent authority of the other State party, as soon as this Convention, Convention or Protocol comes into force, the provisions of the corresponding paragraph of the convention, agreement or protocol with that third country, and, at the request of the competent authority of the other State party, the provisions of this paragraph apply in accordance with this Convention from that entry into force. 6. A business in a contracting state is not considered a stable institution in the other contracting state solely because it acts in that other contracting state through a broker, general agent or other agent with an independent function, provided that they act in due form. However, if the activities of such an agent are entirely or almost entirely intended for that undertaking, he is not considered an independent agent within the meaning of this paragraph if it is shown that the transactions between the representative and the entity were not carried out under the life of the business.
1. Any pension, with another pension within the meaning of Article 19, or any annuity from a contracting state from sources within the other contracting state, is taxable only in the first contracting state. 1. Notwithstanding the provisions of Articles 15 and 16, the income that a State party exercises as an artist, such as a theatre, film, radio or television artist, or a musician or sportsman engaged in his personal activities in the other contracting state, may be taxed in that other State party. 3. Notwithstanding the provisions of this article, the remuneration of a job on board a ship or aircraft operated by a contracting state company operating in international traffic may be taxed in that contracting state. B. When a resident national person receives income that is taxable only in France under the custom agreement, India may put that income on the base, but may, as a deduction of income tax, allow this fraction of the income tax attributable to The income of France.