DT16512 - Double Taxation Relief Manual: Guidance by country: San Marino: Treaty Summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which San Marino is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject	Comments	Article
Portfolio dividends	0% (Note 1)	10
Dividends on direct investments	0% (Note 1)	10
Conditions for lower rate on dividends on direct investments	N/A	10
Property income dividends	15% (Note 1)	10
Interest	0%	11
Royalties	0%	12
Government pensions	Taxable only in San Marino unless the individual is a resident and national of the UK.	19
Other pensions	Taxable only in the UK (Note 2)	17
Arbitration	Yes	24

Note 1: Under the convention, dividends are taxed at 15% where the dividends are paid out of income (including gains) derived directly, or indirectly, from immovable property by an investment vehicle which distributes most of this income annually and and whose income form such immovable property is exempted from tax.

Note 2: Under the convention, pensions and other payments made under the social security legislation of San Marino will be taxable in San Marino.