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San Marino-Vietnam

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Tax Treaty between San Marino and Vietnam has Entered into Force

The income and capital tax treaty between San Marino and Vietnam entered into force on 13 January 2016. The treaty, signed 14 February 2013, is the first of its kind between the two countries.

Taxes Covered

The treaty covers San Marino general income tax on individuals and on bodies corporate and proprietorships. It covers Vietnamese personal income tax, business income tax, and capital tax.

Service PE

The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services in a Contracting State through employees or other engaged personnel if the activities continue for the same or connected project for a period or periods aggregating more than 6 months within any 12-month period.

Withholding Tax Rates

  • Dividends - 10% if the beneficial owner is a company that has directly held at least 10% of the paying company's capital for an uninterrupted period of at least 12 months at the time of the distribution; otherwise 15%
  • Interest - 10% if the beneficial owner is a company that has directly held at least 10% of the paying company's capital for an uninterrupted period of at least 12 months at the time of the payment; otherwise 15%
  • Royalties - 10% if the beneficial owner is a company that has directly held at least 10% of the paying company's capital for an uninterrupted period of at least 12 months at the time of the payment; otherwise 15%
  • Fees for Technical Services (services of a technical, managerial or consultancy nature) - 10%

Capital Gains

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

  • Gains from the alienation of immovable property situated in the other State;
  • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State;
  • Gains from the alienation of shares of the capital stock of a company, or of an interest in a partnership, trust or estate, the property of which consists directly or indirectly principally of immovable property situated in the other Contracting State (principally means the value of such immovable property exceeds 30% of the aggregate value of all assets owned by the company, partnership, trust or estate); and
  • Gains from the alienation of shares, other than those mentioned above, in a company resident in the other State

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Double Taxation Relief

Both countries apply the credit method for the elimination of double taxation. A provision is also included for a tax sparing credit for tax that would otherwise be payable but has been reduced or exempted under legal provisions of a Contracting State for tax incentives for the promotion of economic development.

Effective Date

The treaty applies from 1 January 2017.

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