Legal aspects of double taxation between Malta and Bulgaria

Abstract

This comparative study aims to give an analysis of the concepts and principles of double taxation adopted by the tax systems of Malta and Bulgaria and subsequently how both States provide for double tax treaty relief. The main body of the comparative study analyses the Double Tax Treaty in force between Malta and Bulgaria, and Part II critically examining the existent OECD Model Tax Convention in comparison with the Double Tax Treaty entered into between Malta and Bulgaria. Furthermore, the study delves into the special procedures envisaged by the local laws of Malta and of Bulgaria in the application of the Treaty so that taxpayers can prove the reasoning for the avoidance of double taxation, together with the necessary documentation required by the tax authorities, in the given country, to be applied to the income provisions of the Tax Treaties. Finally, Part IV provides closing comments on the double tax treaty systems in general and gives an overview of the relevant issues of the Treaty and further suggestions for its improvement on the basis of the comparative analysis conducted throughout the research.