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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 17

Pensions

(1) Subject to the provisions of paragraph (2) of Article 18, any pensions and other similar remuneration, paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.

(2) Notwithstanding the provisions of paragraph (1) of this Article, pensions and other similar remuneration paid under the social security laws of a Contracting State shall be taxed only in that State.

(3) Notwithstanding the provisions of paragraph (1) of this Article, pensions and other similar remuneration (including flat rate or lump sum payments) arising in a Contracting State and paid to a resident of the other Contracting State, shall not be taxable in the other Contracting State if these payments arise from contributions or allocations paid or from endowments made in the scope of a complementary pension plan by the beneficiary or on his behalf, provided such contributions, allocations or endowments or the pensions or other similar remuneration were actually subject to tax in the first mentioned Contracting State under the rules of common law.