2021 Andorra-San Marino Income Tax Treaty Available

<p>Tax Analysts has obtained the English text of the Andorra-San Marino income tax treaty signed May 25 in San Marino.</p> <p>Under the treaty, dividends are taxable at 0 percent if the beneficial owner is a company that directly holds at least 10 percent of the capital of the payer company throughout a 365-day period that includes the date of payment of the dividends. A 5 percent rate applies in other cases.</p> <p>Interest is taxable only in the beneficial owner's state of residence, and royalties are subject to a 5 percent tax rate. Both countries generally apply the credit method to eliminate double taxation.</p> <p>This is the first tax treaty between Andorra and San Marino. It will enter into force upon the exchange of ratification instruments and its provisions will apply from January 1 of the year following entry into force.</p>

<p><a href="/lr/resolve//7834v">Catalan text</a>. <a href="/lr/resolve//67zft">Prior coverage</a>.</p>

<p>Tax Analysts has obtained the English text of the Andorra-San Marino income tax treaty signed May 25 in San Marino.</p>

Tax Analysts has obtained the English text of the Andorra-San Marino income tax treaty signed May 25 in San Marino. Under the treaty, dividends are taxable at 0 percent if the beneficial owner is a company that directly holds at least 10 percent of the capital of the payer company throughout a 365-day period that includes the date of payment of the dividends. A 5 percent rate applies in other cases. Interest is taxable only in the beneficial owner's state of residence, and royalties are subject to a 5 percent tax rate. Both countries generally apply the credit method to eliminate double taxation. This is the first tax treaty between Andorra and San Marino. It will enter into force upon the exchange of ratification instruments and its provisions will apply from January 1 of the year following entry into force.

<h4>Rate Table Instructions</h4> <ul> <li>You must enter a rate for each rate type</li> <li>Enter only one rate value per row</li> <li>You may leave the country columns blank if the rate is the same for both countries</li> <li>Country names (if entered) must exactly match the jurisdictions</li> <li>Leave the Partner Country column blank if you want the rate to apply to all partners of the Main Country</li> <li>Enter "n/a" in each rate row to hide the partner in the Main Country table</li> <li>Note that the same rates may apply for Main Country and Partner Country or the Main Country may apply different rates to the Partner Country</li> </ul> <table> <tbody> <tr> <th> <div>Rate Type</div> (Dividends, Interest, Royalties)</th> <th>Main Country</th> <th>Partner Country</th> <th>Rate</th> <th>Footnote 1</th> <th>Footnote 2</th> <th>Footnote 3</th> <th>Footnote 4</th> </tr> <tr> <td>Dividends</td> <td> </td> <td> </td> <td>0/5</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Interest</td> <td> </td> <td> </td> <td>0</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Royalties</td> <td> </td> <td> </td> <td>5</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> </tbody> </table>

Andorra - San Marino: 2021 Income Tax Convention and Final Protocol

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2021 Andorra-San Marino Income Tax Treaty Available