Relief at source – eligibility, documentation, deadlines – Bulgarian equities

11.10.2023

Who can obtain relief at source?

Tax relief at source on dividends from Bulgarian equities is available through Clearstream Banking1, provided that the final beneficial owner is resident in country member of European Union / European Economic Area (EU/EEA).

Note: Beneficial owners that are residents in a country that has signed a DTT with Bulgaria but that is not an EU/EEA member cannot apply for tax relief at source on Bulgarian dividends. However, such beneficial owners may recover the tax withheld at source through the standard reclaim procedure, if applicable certification requirements are met.

Documentation requirements

In order to benefit from tax relief at source on dividends from Bulgarian equities, clients must ensure to provide Clearstream Banking with the following documents within the applicable deadlines. The related templates of the documents are available on our Tax forms to use section.

For all clients applying for tax relief at source on dividends from Bulgarian equities:

  • One-Time Certificate for Bulgarian Withholding Tax purposes, in the name of the Clearstream Banking client;
  • Certificate of residence, in the name of the final beneficial owner(s).

In addition, for Clearstream Banking clients that are holding the Bulgarian equities on behalf of third parties:

  • Declaration(s) of the beneficiary, in the name of the last intermediary in the chain having the final beneficial owner in its books;
  • Cover letter, in the name of Clearstream Banking client and only in case the last intermediary in the chain is not the Clearstream Banking client;
  • List of beneficial owners.

Deadlines for receipt of documents

In order to benefit from tax relief at source on dividends from Bulgarian equities, Clearstream Banking clients should provide the required documentation within the below prescribed deadlines. If any documentation is received after these deadlines, the client’s entire application for tax relief at source will be rejected.

Equities

Deadline

Relief at source(a)

One Time Certificate

7 BD after the RD, 10;00 CET

Certificate of Residence

7 BD after the RD, 10;00 CET

Declaration of the beneficiary

7 BD after the RD, 10;00 CET

Cover letter

7 BD after the RD, 10;00 CET

List of Beneficial Owners (LBO)

7 BD after the RD, 10;00 CET

(a) Clearstream Banking informs clients that it is fully dependent on the information provided by its depository with regard to the tax relief at source procedure. Due to current uncertainty on the deadlines for relief at source set up by the depository, the relief at source service is provided on a “best efforts” basis only until Clearstream Banking’s depository provides clear and unequivocal deadlines. Should clients miss the deadline to apply for relief at source, Clearstream Banking recommends that they initiate their tax reclaim as soon as possible after the taxable income payment date.

-------------

1. Clearstream Banking refers collectively to Clearstream Banking S.A. and Clearstream Banking AG (for Clearstream Banking AG clients using Creation accounts).