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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

PROTOCOL TO THE CONVENTION BETWEEN THE REPUBLIC OF SAN MARINO AND THE HELLENIC REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

When signing the Convention concluded today between the Republic of San Marino and the Hellenic Republic for the avoidance of double taxation with respect to taxes on income and on capital, the following additional provisions forming integral part of this Convention have been agreed upon.

(1) With respect to paragraph (1), point (e) of Article 3, in San Marino a trust shall be treated as a body corporate for tax purposes where and only to the extent in which such trust is subject to San Marino income tax.

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

(3) It is understood that in this Convention nothing shall prevent the application of the relative provisions of the EU Directives inserted in the domestic legislation of both Contracting States. In order to settle the above the competent authorities of both States shall exchange letters.

DONE in duplicate at San Marino, this twenty-sixth day of June 2013, each in the Italian, Greek and English languages, all texts being equally authentic. In case of divergence between the texts the English text shall prevail.

FOR THE REPUBLIC OF SAN MARINO:

PASQUALE VALENTINI

MINISTER OF FOREIGN AFFAIRS

FOR THE HELLENIC REPUBLIC:

THEMISTOKLIS DEMIRIS

AMBASSADOR OF THE HELLENIC REPUBLIC