The Double Taxation Relief and International Tax Enforcement (San Marino) Order 2023

The Double Taxation Relief and International Tax Enforcement (San Marino) Order 2023 was published on legislation.gov.uk, the official legislative journal of the UK government. The order implements the agreement concluded between the United Kingdom and the Republic of San Marino on May 17, 2023 in relation to the elimination of double taxation between the two nations while preventing tax evasion and avoidance. On the part of UK, the agreement applies to taxes on income, corporation tax, and capital gains tax, including interest income, income from dividends and royalties, business profits, employment income, and several others. On the part of San Marino, it applies to „income tax on individuals, on bodies corporate and proprietorships“.
The order entirely eliminates double taxation with key provisions outlined in the enclosed schedule. This is the first comprehensive tax treaty with San Marino and largely follows the OECD model, although some major differences exist and are outlined in the accompanying explanatory memorandum. The order will enter into force once both countries have notified each other in writing through diplomatic channels of the completion of the procedures required by domestic law for the bringing into force the new double taxation agreement.