San Marino

San Marino has 22 tax agreements in force, as reported in its response to the Peer Review questionnaire. Its agreement with Serbia complies with the minimum standard.

San Marino signed the MLI in 2017, listing 21 tax agreements.1

San Marino is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

No jurisdiction has raised any concerns about their agreements with San Marino.


← 1. In total, San Marino listed 22 agreements under the MLI, one of which (the agreement with the United Arab Emirates) is not yet in force.

← 2. For its agreements listed under the MLI, San Marino is implementing the preamble statement (Article 6 of the MLI). For 18 of its agreements listed under the MLI, San Marino is implementing the PPT (Article 7 of the MLI). San Marino made a reservation pursuant to Article 7(15)(b) not to apply Article 7(1) with respect to agreements which already contain a PPT. Three of San Marino’s agreements are within the scope of this reservation.

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