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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 imposed on behalf of a Contracting State or of its political or administrative subdivisions 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, 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 this Convention shall apply are:

  • (a) in Barbados:
    • (i) the income tax (including premium income tax);
    • (ii) the corporation tax (including the tax on branch profits); and
    • (iii) the petroleum winning operation tax;
  • (hereinafter referred to as "Barbados tax").
  • (b) in San Marino: the general income tax which is levied:
    • (i) on individuals;
    • (ii) on bodies corporate and proprietorships even if collected through a withholding tax;
  • (hereinafter referred to as "San Marino tax");

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