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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.

PROTOCOL

At the moment of signing the "Agreement between Georgia and the Republic of San Marino for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital", the undersigned have agreed that the following provisions shall form an integral part of the Agreement.

It is understood that:

(1) With reference to Article 2, paragraph (1), in the case of Georgia, the term "political subdivisions" or "local authorities" means "administrative-territorial units" or "local self governing authorities";

(2) With reference to Article 5, paragraph (2), a "permanent establishment" may include a server.

IN WITNESS WHEREOF, the undersigned, duly authorised thereto, have signed this Protocol.

DONE in duplicate at New York this 28th day of September 2012, in Georgian, Italian and English languages, all three texts being equally authentic. In the case of divergence of interpretation the English text shall prevail.

FOR GEORGIA:

GRIGOL VASHADZE

FOR THE REPUBLIC OF SAN MARINO:

ANTONELLA MULARONI