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San Marino - Seychelles Tax Treaty (as amended by 2014 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 3

General Definitions

(1) For the purposes of this Agreement, unless the context otherwise requires:

  • (a) the term "San Marino" means the territory of the Republic of San Marino, including any other area within which the Republic of San Marino, in accordance with international law, exercises sovereign rights or jurisdiction;
  • (b) the term "Seychelles" means the territory of the Republic of Seychelles including its exclusive economic zone and continental shelf where Seychelles exercises sovereign rights and jurisdiction in conformity with the provisions of the United Nations Agreement on the Law of the Sea;
  • (c) the terms "a Contracting State" and "the other Contracting State" mean San Marino or Seychelles, as the context requires;
  • (d) the term "person" includes an individual, a company and any other body of persons that is treated as an entity for tax purposes;
  • (e) the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;
  • (f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (g) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise that has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (h) the term "national" means:
    • (i) any individual possessing the nationality or citizenship of a Contracting State; and
    • (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State;
  • (i) the term "competent authority" means:
    • (i) in San Marino, the Ministry of Finance or its authorised representative, and, for the purposes of Article 25 "Exchange of information", the Central Liaison Office of the Republic of San Marino;
    • (ii) in Seychelles, the Minister of Finance or an authorised representative of the Minister of Finance.

(2) As regards the application of the Agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.