Article 1
Persons covered
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Website Last updated:
June 26, 2026
Agreement between the Government of the REPUBLIC OF SAN MARINO and the Government of the UNITED ARAB EMIRATES for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
[GTL Notes - See Protocol]
The Government of the Republic of San Marino and the Government of the United Arab Emirates,
Desiring to promote their mutual economic relations and to enhance their cooperation in tax matters through the conclusion between them of an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income,
Have agreed as follows:
Contents
Article 1 - Persons covered
Article 2 - Taxes covered
Article 3 - Income from hydrocarbons
Article 4 - General definitions
Article 5 - Resident
Article 6 - Permanent establishment
Article 7 - Income from immovable property
Article 8 - Business profits
Article 9 - Shipping and Air Transport
Article 10 - Associated enterprises
Article 11 - Dividends
Article 12 - Interest
Article 13 - Royalties
Article 14 - Capital gains
Article 15 - Income from employment
Article 16 - Directors' fees
Article 17 - Artistes and sportsmen
Article 18 - Pensions
Article 19 - Government service
Article 20 - Students and Business Apprentices
Article 21 - Other income
Article 22 - Elimination of double taxation
Article 23 - Non-discrimination
Article 24 - Mutual agreement procedure
Article 25 - Exchange of information
Article 26 - Limitation of Benefits
Article 27 - Miscellaneous Rules
Article 28 - Income of Government and Institutions
Article 29 - Members of diplomatic missions and consular posts
Article 30 - Refunds
Article 31 - Entry into force
Article 32 - Termination
Protocol