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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.


Taxes Covered

(1) This Convention shall apply to taxes on income imposed by a Contracting State, one of its political subdivisions or 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 amount of wages or salaries paid by enterprises as well as taxes on capital appreciation.

(3) The existing taxes to which this Convention shall apply are, in particular:

  • (a) in the case of the Republic of San Marino:
    • (i) the tax on income of individuals (l'imposta sul reddito delle persone fisiche);
    • (ii) the tax on income of bodies corporate and proprietorships (l'imposta sul reddito delle persone giuridiche e delle imprese individuali);
  • (hereinafter referred to as "San Marino tax");
  • (b) in the case of the Italian Republic:
    • (i) the personal income tax (l'imposta sul reddito delle persone fisiche);
    • (ii) the corporate income tax (l'imposta sul reddito delle persone giuridiche);
    • (iii) the regional tax on productive activities (l'imposta regionale sulle attività produttive)
  • whether or not they are collected by withholding at source;
  • (hereinafter referred to as "Italian tax").

(4) This Convention shall also apply to taxes of an identical or substantially similar nature that are imposed after the date of signature of this Convention in addition to, or instead of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes made in their respective tax laws.