background image
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 and on capital imposed on behalf of a Contracting State, a political subdivision or of its local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Agreement shall apply are in particular:

  • (a) in Vietnam:
    • (i) the personal income tax;
    • (ii) the business income tax; and
    • (iii) the capital tax (if any);
  • (hereinafter referred to as "Vietnamese tax"); and
  • (b) in San Marino: the general income tax which is levied:
    • (i) on individuals; and
    • (ii) on bodies corporate and proprietorships;
  • even if collected through a withholding tax.
  • (hereinafter referred to as "San Marino tax").

(4) The Agreement shall also apply to any identical or substantially similar taxes that 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.