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Luxembourg - San Marino Tax Treaty (as amended by 2009 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 22

Capital

(1) Capital represented by immovable property referred to in Article 6 which is held by a resident of a Contracting State and which is situated in the other Contracting State shall be taxable in that other State.

(2) Capital represented by movable property which belongs to the assets of a permanent establishment which an enterprise of a Contracting State maintains in the other Contracting State shall be taxable in that other State.

(3) Capital represented by ships and aircraft operated in international traffic, by boats used for internal navigation as well as by movable property used in the operation of these ships, aircraft or boats shall be taxable only in the Contracting State where the place of effective management of the enterprise is situated.

(4) All other items of capital of a resident of a Contracting State shall only be taxable in that State.