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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.


Taxes Covered

(1) This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political or administrative-territorial subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital or on elements of income or capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are in particular:

  • (a) in the case of the Republic of San Marino:
  • the general income tax which is levied:
    • (i) on individuals;
    • (ii) on bodies corporate and proprietorships;
  • (hereunder referred to as "San Marino tax");
  • (b) in the case of the Republic of Azerbaijan:
    • (i) the tax on profit of legal persons;
    • (ii) the income tax of physical persons;
    • (iii) the tax on property; and
    • (iv) the land tax;
  • (hereunder referred to as "Azerbaijan tax").

(4) The Convention shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of this Convention 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 that have been made in their taxation laws.