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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.


Limitation of Benefits

(1) Notwithstanding the other provisions of this Convention, a resident of a Contracting State may not receive from that Contracting State the benefits of fiscal reductions or exemptions provided for in this Convention, if the main purpose or one of the main purposes of constitution or existence of such resident or of any individual connected to such resident, was to avail of the benefits provided for in this Convention, to which this resident would not have recourse to otherwise.

(2) The provisions of this Convention shall not affect the application of the internal rules with respect to limitation of expenditure and other deductions derived from transactions carried on between the enterprises of a Contracting State and enterprises of the other Contracting State.