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San Marino - Italy 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 19

Government Service

(1)

  • (a) Remuneration other than pensions, paid by a Contracting State, one of its political or administrative sub-divisions or local authorities, to an individual in respect of services rendered to that Contracting State, political or administrative sub-division or local authority, shall be taxable only in that State.
  • (b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the individual who is a resident of that State:
    • (i) is a national of that Contracting State; or
    • (ii) did not become a resident of that State solely for the purpose of rendering such services.

(2)

  • (a) Any pension paid by, or out of funds created by, a Contracting State or one of its political or administrative sub-divisions or local authorities, to an individual in respect of services rendered to that State, political or administrative sub-division or local authority, shall be taxable only in that State.
  • (b) However, such pensions shall be taxable only in the other Contracting State if the individual is a resident and a national of that State.

(3) The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pensions paid in respect of services rendered in connection with a business carried on by a Contracting State or by one of its political or administrative sub-divisions or local authorities.