background image

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 14

Independent Personal Services

(1) Income derived by a resident of a Contracting State in respect of professional services or other independent activities of similar nature shall be taxable in that State. Such income may also be taxable in the other Contracting State in accordance with the domestic laws of that other State.

(2) The term "professional services" includes independent scientific, literary, artistic educational or teaching activities, as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.