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San Marino - Qatar Tax Treaty (2013, not yet in force) — 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 23

Elimination of Double Taxation

(1) It is agreed that double taxation shall be avoided in accordance with the following paragraphs of this Article.

(2) In Qatar:

  • Where a resident of Qatar derives income which, in accordance with the provisions of this Agreement, is taxable in San Marino, then Qatar shall allow as a deduction from the tax on income of that resident an amount equal to the tax paid in San Marino provided that such deduction shall not exceed that part of the tax, as computed before the deduction is given, which is attributable to the income derived from San Marino.

(3) In San Marino:

  • (a) Where a resident of San Marino derives income which, in accordance with the provisions of this Agreement, may be taxed in Qatar, San Marino shall, subject to the provisions of paragraph (b), exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt.
  • (b) Where a resident of San Marino derives income which, in accordance with the provisions of Article 12, may be taxed in Qatar San Marino shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Qatar. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Qatar.

(4) For the purposes of paragraphs (2) and (3) of this Article, the term "tax paid" shall be deemed to include the amount of tax which would have been paid in a Contracting State, had an exemption or reduction granted in accordance with the laws and regulations of that Contracting State not be granted.