San Marino

San Marino has 23 tax agreements in force, as reported in its response to the Peer Review questionnaire. One of those agreements, the agreement with Serbia, complies with the minimum standard.

San Marino signed the MLI in 2017 and deposited its instrument of ratification on 11 March 2020, listing its non-compliant agreements. The MLI will enter into force for San Marino on 1 July 2020.

San Marino is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1

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. For its agreements listed under the MLI, San Marino is implementing the preamble statement (Article 6 of the MLI). For 19 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) of the MLI not to apply Article 7(1) of the MLI 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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