background image

San Marino - Croatia Tax Treaty (as amended by 2012 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.

ARTICLE 2

Taxes Covered

(1) This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its 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 and salaries paid by enterprises, as well as taxes on capital appreciation.

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

  • (a) in the Republic of San Marino:
  • the general income tax which is levied
    • (1) on individuals;
    • (2) on bodies corporate and proprietorships; even if collected through a withholding tax
  • (hereunder referred to as "San Marino tax");
  • (b) in the Republic of Croatia:
    • (1) the profit tax;
    • (2) the income tax;
    • (3) the local income tax and any other surcharge levied on one of these taxes;
  • (hereunder referred to as "Croatian tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of this Agreement 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.