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.
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.
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.
The following capital gains derived by a resident of one Contracting State may be taxed by the other State:
Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.
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.
The treaty applies from 1 January 2017.
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