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Cyprus - San Marino Tax Treaty (as amended by 2017 protocol) — Orbitax Tax Hub

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 the Convention shall apply are in particular:

  • (a) in the case of 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;
  • (hereunder referred to as "San Marino tax");
  • (b) in the case of Cyprus:
    • (i) the income tax;
    • (ii) the corporate income tax;
    • (iii) the special contribution for the defence of the Republic; and
    • (iv) the capital gains tax even if collected through a withholding tax;
  • (hereunder referred to as "Cyprus 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.