Bulgaria Bulgarian Tax Agreements and International Agreements A new agreement to replace the existing agreement with Germany was signed on 30 March 2011. This agreement came into force on November 28, 2012 and comes into effect on January 1, 2013. Ireland has completed ratification procedures for the entry into force of the new agreements with Kuwait, Panama and Saudi Arabia. If these countries finalize the ratification procedures, the agreements will enter into force. A protocol to the existing agreement with South Africa came into force on 10 February 2012 and comes into force from 1 April 2012 for Articles III and VI of the Protocol and from 1 January 2013 for other articles. Ireland has completed ratification procedures for the entry into force of the protocol to the existing agreement with Malaysia. If Malaysia has also completed the ratification procedures, the protocol will enter into force. A protocol to the existing agreement with Switzerland was signed on 26 January 2012. The legal procedures for entering into force of this protocol are now being followed. Negotiations on new agreements with Thailand and Ukraine have been completed and are expected to be signed shortly.
Negotiations on the protocols with existing agreements with Belgium and Luxembourg have also been concluded. When a Polish resident earns income in a foreign country that has no DTT with Poland, double taxation is avoided on the basis of the credit method. The Polish resident is responsible for income tax levied on his or her world income, but this tax is reduced proportionally by income tax paid abroad. Many DTTs offer the same method of credit. However, some of them provide for the method of exemption (i.e. foreign income covered by this contract is exempt from taxation in Poland). The specific provisions for border workers are contained in the following double taxation conventions: negotiations for new agreements with the following countries take place at different stages: Azerbaijan and Tunisia. Negotiations are under way to review existing agreements with Pakistan and the Netherlands. In addition, negotiations on new agreements with other countries are expected to begin in 2012.
If there is no double taxation agreement with a particular country, there are provisions of the 1997 Irish Taxes Consolidation Acts (TCA) that allow for a unilateral exemption from double taxation for certain types of income. The main provisions that grant unilateral relief are: dividends paid by foreign subsidiaries: credit for withholding tax on dividends and foreign taxes, payments on underlying earnings from which dividends were paid (point 9A and B of Schedule 24 TCA 1997) merged and transferred from excess foreign tax credits (point 9E of Schedule 24 TCA 1997) Consolidated Tax (item 9G of Schedule 24 TCA 1997) new income tax agreement between Ireland and the Irish authorities The Netherlands was signed on 13 June 2019.