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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 Agreement shall apply to taxes on income imposed on behalf of a Contracting State, 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 totals amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes which are the subject of this Agreement are:

  • (a) in Malaysia:
    • (i) the income tax; and
    • (ii) the petroleum income tax;
  • (hereinafter referred to as "Malaysian tax");
  • (b) in San Marino: the general income tax which is levied:
    • (i) on individuals;
    • (ii) on bodies corporate and proprietorships;
  • (hereinafter referred to as "San Marino tax").

(4) This Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.