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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 2

Taxes Covered

(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or any of its local governments or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property.

(3) The existing taxes to which this Agreement shall apply are:

  • (a) in the case of San Marino:
    • (i) the taxes imposed by the Government of San Marino under the General Income Tax which is levied:
      • (i) on individuals;
      • (ii) on any other persons other than individuals;
  • (hereinafter referred to as "San Marino tax"); and
  • (b) in the case of UAE:
    • (i) the income tax;
    • (ii) the corporate tax;
  • (hereinafter referred to as “UAE tax”).

(4) The Agreement shall apply also to any identical taxes or substantially similar taxes imposed after the date of the signature of this Agreement, in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their taxation laws.