1. Where a person considers that the conduct of one or both Contracting States will result in or will result in taxation which is not in conformity with the provisions of this Convention, he may, irrespective of the remedies provided for by the domestic law of those States, submit his case to the competent authority of the Contracting State in which he resides or if his case falls within the scope of paragraph 1 of Article 25: in the case of the State Party of which he is a national. The case must be submitted within three years of the first notification of the appeal leading to non-taxation in accordance with the provisions of the Agreement. Agreement between the Government of the Russian Federation and the Government of the Republic of Albania for the avoidance of double taxation on income and capital (d) If he is a national of both States or of either State, the competent authorities of the States Parties shall decide by mutual agreement on the matter. Ireland has signed comprehensive double taxation (SAA) conventions with 74 countries; 73 are in force. 1. The competent authorities of the Contracting States shall exchange the information necessary for the application of the provisions of this Convention or of the domestic law of the Contracting States in relation to taxes covered by the Convention, in so far as the taxation is not contrary to the Convention. Article 1 does not limit the exchange of information. All information received by a State Party shall be treated in the same manner as information obtained under the national law of that State and may be communicated only to persons or authorities (including courts and administrative bodies) who are responsible for the assessment or collection, enforcement or prosecution of or the decision to appeal in respect of taxes subject to of the Convention. Such persons or authorities may only use this information for that purpose.
You may disclose the information as part of a public legal proceeding or court order. Below is a summary of the ongoing work on the negotiation of new BBs and the updating of existing agreements: 1. Nationals of a Contracting State may not be subject in the other State Party to any taxation or requirement that is different or more onerous than the taxation and related requirements to which nationals of that other State are subject in the same circumstances. in particular with regard to the place of residence, are or may be subject. Without prejudice to Article 1, this provision shall also apply to persons who are not resident in one or both Contracting States. The taxation of dividends, interest and royalties in the country of origin is limited to 3% of the gross payment. In the case of interest and royalties, certain payments are exempt, for example. Β interest on loans granted by a bank or other financial institution or on cultural and scientific royalties. Bulgaria Bulgarian tax treaties and international agreements Nothing in this Convention shall affect the tax privileges of members of diplomatic missions or consular representations, in accordance with the general rules of international law or the provisions of special agreements.
3. The competent authorities of the Contracting States shall endeavour to eliminate by mutual agreement all difficulties or doubts which arise in the interpretation or application of this Convention. . . .