Common use of METHODS FOR ELIMINATION OF DOUBLE TAXATION Clause in Contracts

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of San Marino, double taxation shall be avoided as follows : a) Where a resident of San Marino derives income which, in accordance with the provisions of this Convention, may be taxed in Belgium, San Marino shall, subject to the provisions of sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Belgium. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in San Marino in accordance with the provisions of this Convention, and which are taxed there, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. However, in the case of a company which is a resident of Belgium, where the San Marino tax is less than 15 per cent of the net amount of the income referred to in this provision, Belgium shall not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. b) Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels - beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in San Marino have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino by reason of compensation for the said losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of San MarinoEstonia, double taxation shall be avoided as follows follows: a) Where where a resident of San Marino Estonia derives income which, in accordance with the provisions of this ConventionAgreement, may be has been taxed in BelgiumKyrgyzstan, San Marino Estonia shall, subject to the provisions of sub-paragraphs paragraph b) and c) ), exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt.tax; b) Where where a resident of San Marino Estonia derives income which, which in accordance with the provisions of sub-paragraph b) of paragraph 2 of Article 10, or paragraph 2 of Articles 10 and 11, 11 or 12 may be taxed in BelgiumKyrgyzstan, San Marino Estonia shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the tax paid in BelgiumKyrgyzstan. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in San Marino Kyrgyzstan; c) where in accordance with any provision of the provisions Agreement income derived by a resident of this Convention, and which are taxed there, Belgium shall Estonia is exempt such income from tax but mayin Estonia, Estonia may nevertheless, in calculating the amount of tax on the remaining income of that such resident, apply the rate of tax which would have been applicable if such income had not been exempted. However, in the case of a company which is a resident of Belgium, where the San Marino tax is less than 15 per cent of the net amount of the income referred to in this provision, Belgium shall not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. b) Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned exempted income. 2. In Kyrgyzstan, double taxation shall be avoided as follows: a) Where a resident of Kyrgyzstan derives income (revenus professionnels - beroepsinkomsten) that is exempted from tax in Belgium which, in accordance with sub-paragraph a) the provisions of this paragraphAgreement, may be taxed in Estonia Kyrgyzstan shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Estonia. These additional taxes The amount of the tax deducted in accordance with the aforementioned provisions shall not exceed the tax, which would have been charged to this income by the rates effective in Kyrgyzstan. b) Where a resident of Kyrgyzstan derives income which in accordance with the provisions of this Agreement shall be calculated on taxable only in Estonia, Kyrgyzstan may include this income in the tax which would be payable base, but only for the purpose of establishing the tax rate for such income being applicable for taxation in Belgium if the earned income in question had been derived from Belgian sourcesKyrgyzstan. c) Dividends derived by 3. Notwithstanding the provisions of paragraphs 1 and 2, where a company which that is a resident of Belgium a Contracting State receives a dividend from a company which that is a resident of San Marino the other Contracting State in which it owns at least 10 per cent of its shares having full voting rights, the first-mentioned State shall be exempt allow as a deduction from the corporate tax of that resident an amount equal to the income tax paid in Belgium under that other State by the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino tax levied company on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in San Marino have been effectively deducted from the profits out of that enterprise for its taxation in Belgium, which the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino by reason of compensation for the said lossesdividend is paid.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of San Marinothe Isle of Man, double taxation shall be avoided as follows follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Guernsey. b) Where a resident of San Marino the Isle of Man derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in Belgium, San Marino shall, subject to Guernsey the provisions Isle of sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino Man shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in BelgiumGuernsey. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in San Marino Guernsey. c) Where in accordance with the provisions any provision of this Convention, and which are taxed there, Belgium shall Agreement income derived by a resident of the Isle of Man is exempt such income from tax but mayin the Isle of Man, the Isle of Man may nevertheless in calculating the amount of tax on the remaining income of that such resident, apply take into account the rate of tax which would have been applicable if such income had not been exemptedexempted income. 2. However, in In the case of a company which is a resident of BelgiumGuernsey, where double taxation shall be avoided as follows: Subject to the San Marino tax is less than 15 per cent provisions of the net amount laws of Guernsey regarding the income referred to allowance as a credit against Guernsey tax of tax payable in this provision, Belgium a territory outside Guernsey (which shall not exempt that income, but reduce affect the general principle hereof): a) subject to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. b) Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels - beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad), where a resident of Belgium Guernsey derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Wherewhich, in accordance with Belgian lawthe provisions of the Agreement, losses incurred by may be taxed in the Isle of Man, Guernsey shall allow as a deduction from the tax payable in respect of that income, an enterprise carried on by amount equal to the income tax paid in the Isle of Man; b) such deduction shall not, however, exceed that part of the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in the Isle of Man; c) where a resident of Belgium Guernsey derives income which, in a permanent establishment situated accordance with the provisions of the Agreement shall be taxable only in San Marino have been effectively deducted from the profits Isle of that enterprise for its taxation Man, Guernsey may include this income in Belgium, calculating the exemption provided for in sub-paragraph a) shall not apply in Belgium to amount of tax on the profits remaining income of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino by reason of compensation for the said lossessuch resident.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In The laws in either of the case contracting states shal continue to govern the taxation of San Marinoincome in the respective Contracting States except where provisions to the contrary are made in this Agreement. Where income is subject to tax in both contracting states, relief from double taxation shall shal be avoided given in accordance with this Article. 2. Double taxation shal be eliminated as follows fol ows: (i) In India: (a) Where a resident of San Marino India derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in BelgiumBhutan, San Marino shall, subject to the provisions of sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino shall allow India shal al ow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in BelgiumBhutan. Such deduction shall shal not, however, exceed that part portion of the income tax, tax as computed before the deduction is given, which is attributable attributable, as the case may be, to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in San Marino Bhutan. (b) Where in accordance with any provision of the provisions Agreement income derived by a resident of this Convention, and which are taxed there, Belgium shall India is exempt such income from tax but mayin India, India may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. (ii) In Bhutan: (a) Where a resident of Bhutan derives income which, in accordance with the provisions of this Agreement, may be taxed in India, Bhutan shal al ow as a deduction from the tax on the income of that resident, apply an amount equal to the rate tax paid in India. Such deduction shal not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in India. (b) Where in accordance with any provision of the Agreement, income derived by a resident of Bhutan is exempt from tax in Bhutan, Bhutan may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income. 3. The tax payable by an enterprise (being a permanent establishment) in Bhutan mentioned in paragraphs 1 and 2 of this ARTICLE shal be deemed to include the tax which would have been applicable if such income had not been exemptedpayable but for the fol owing tax incentives in education and health sectors granted under the Fiscal Incentives, 2010 issued by Ministry of Finance, Royal Government of Bhutan (vide Notification Ref No. HoweverDRC/XXX­X&X/HOL/2010/3656 dated 2nd April, 2010) which are designed to promote economic development in the case Bhutan: (i) Education sector: An educational or vocational institute established outside Thimphu and Phuentsholing cities (with a minimum enrofment capacity of 200 students); (ii) Health sector: A high end private health service centre or hospital (with a company which is a resident minimum project cost of Belgium, where the San Marino tax is less than 15 per cent of the net amount of the income referred to in this provision, Belgium shall not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sourcesRs/Nu 200 mil ion). b) 4. Notwithstanding the provisions of sub-paragraph a) 3, Bhutanese tax shal not be deemed to have been paid under that paragraph of this paragraph and any other provision ARTICLE in respect of: (i) income by way of this Conventiondividends, Belgium shallinterest, for capital gains or from activities not directly connected with the determination running of educational or vocational institute or health service centre or hospital, as the additional taxes established by Belgian municipalities and conurbations, take into account the earned case may be; or (ii) income (revenus professionnels - beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c) Dividends derived any arrangement, entered into by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to an Indian resident, covered by the provisions of Belgian law regarding ARTICLE 27(Limitation of Benefits) of the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such incomeAgreement. e) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident 5. The provisions of Belgium in a permanent establishment situated in San Marino have been effectively deducted paragraph 3 shal apply for the first seven years from the profits date of that enterprise for its taxation in Belgium, entry into force of this Agreement. This period may be extended by mutual agreement between the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino by reason of compensation for the said lossescompetent authorities.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of San Marinothe Isle of Man, double taxation shall be avoided as follows follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Belgium. b) Where a resident of San Marino the Isle of Man derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in Belgium, San Marino shall, subject to Belgium the provisions Isle of sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino Man shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Belgium. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising which may be taxed in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held the Isle of Man holds, for an uninterrupted period of at least 25 percent twelve months, directly at least 10 per cent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino the Isle of Man shall exempt from tax the dividends paid to the company which is a resident of San Marino the Isle of Man by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows follows: a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in San Marino the Isle of Man in accordance with the provisions of this ConventionAgreement, and which are taxed there, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. However, in the case of a company which is a resident of Belgium, where the San Marino Manx tax is less than 15 10 per cent of the net amount of the income referred to in this provisionsub-paragraph, Belgium shall not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. The preceding provisions of this sub-paragraph shall also apply to income treated as dividends under Belgian law, which is derived by a resident of Belgium from a participation in an entity that derives its status as such from the laws of the Isle of Man, where that entity has not been taxed as such in the Isle of Man, provided that the resident of Belgium has been taxed in the Isle of Man on his share of the income of that entity. The exempted income is the income received after deduction of the costs incurred in Belgium or elsewhere in relation to the management of the participation in the entity. b) Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this ConventionAgreement, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels - or beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino the Isle of Man shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. However, this exemption shall apply when the income out of which the dividends are paid is taxed in the Isle of Man at a rate of not less than 10 per cent. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino Manx tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in San Marino the Isle of Man have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino the Isle of Man by reason of compensation for the said losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. Subject to the provisions of Luxembourg law regarding the elimination of double taxation which shall not affect the general principle hereof, double taxation shall be eliminated as follows: a) where a resident of Luxembourg derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in the Isle of Man, Luxembourg shall, subject to the provisions of sub-paragraphs b), c) and d), exempt such income or capital from tax, but may, in order to calculate the amount of tax on the remaining income or capital of the resident, apply the same rates of tax as if the income or capital had not been exempted; b) where a resident of Luxembourg derives income which, in accordance with the provisions of Articles 7, 10, 13(2) and 16 may be taxed in the Isle of Man, Luxembourg shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in the Isle of Man, but only, with respect to Articles 7 and 13(2), if the business profits and the capital gains are not derived from activities in agriculture, industry, infrastructure and tourism in the Isle of Man. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from the Isle of Man; c) where a company which is a resident of Luxembourg derives dividends from Isle of Man sources, Luxembourg shall exempt such dividends from tax provided that the company which is a resident of Luxembourg holds directly at least 10 per cent of the capital of the company paying the dividends since the beginning of the accounting year and if this company is subject to the Isle of Man tax corresponding to the Luxembourg corporation tax. The above-mentioned shares in the Isle of Man company are, under the same conditions, exempt from the Luxembourg capital tax. This exemption under this sub-paragraph shall also apply notwithstanding that the Isle of Man company is exempted from tax or taxed at a reduced rate in the Isle of Man and if these dividends are derived out of profits from activities in agriculture, industry, infrastructure or tourism in the Isle of Man; d) the provisions of sub-paragraph a) shall not apply to income derived or capital owned by a resident of Luxembourg where the Isle of Man applies the provisions of this Agreement to exempt such income or capital from tax or applies the provisions of paragraph 2 of Article 10 to such income. 2. In the case of San Marinothe Isle of Man, double taxation shall be avoided as follows follows: a) When imposing tax on its residents the Isle of Man may include in the basis upon which such taxes are imposed the items of income, which, according to the provisions of this Agreement, may be taxed in Luxembourg. b) Where a resident of San Marino the Isle of Man derives income which, in accordance with the provisions of this ConventionAgreement, may be taxed in Belgium, San Marino shall, subject to Luxembourg the provisions Isle of sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino Man shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in BelgiumLuxembourg. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in San Marino Luxembourg. c) Where in accordance with the provisions any provision of this Convention, and which are taxed there, Belgium shall Agreement income derived by a resident of the Isle of Man is exempt such income from tax but mayin the Isle of Man, the Isle of Man may nevertheless in calculating the amount of tax on the remaining income of that such resident, apply the rate of tax which would have been applicable if such income had not been exempted. However, in the case of a company which is a resident of Belgium, where the San Marino tax is less than 15 per cent of the net amount of the income referred to in this provision, Belgium shall not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. b) Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels - beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) income. Note 24: The Isle of Man has reserved the right for the entirety of Articles 3 and 5 of the MLI not to apply to this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in San Marino Agreement so there have been effectively deducted from no changes to this Article notwithstanding that Luxembourg has decided to apply Option A of Article 5 of the profits MLI. Luxembourg has reserved the right for paragraph 2 of that enterprise for its taxation in Belgium, Article 3 of the exemption provided for in sub-paragraph a) shall MLI not to apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino by reason of compensation for the said lossesthis Agreement.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of San Marino, double taxation shall be avoided as follows : a) Where a resident of San Marino derives income which, in accordance with the provisions of this Convention, may be taxed in Belgium, San Marino shall, subject to the provisions of sub-paragraphs b) and c) exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt. b) Where a resident of San Marino derives income which, in accordance with the provisions of Articles 10 and 11, may be taxed in Belgium, San Marino shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Belgium. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of Belgium. 2. In the case of Belgium, double taxation shall be avoided as follows : a) Where a resident of Belgium derives income, not being dividends, interest or royalties, which may be taxed in San Marino in accordance with the provisions of this Convention, and which are taxed there, Belgium shall exempt such income from tax but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted. However, in the case of a company which is a resident of Belgium, where the San Marino tax is less than 15 per cent of the net amount of the income referred to in this provision, Belgium shall not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. b) Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels - – beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in San Marino have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino by reason of compensation for the said losses.

METHODS FOR ELIMINATION OF DOUBLE TAXATION. 1. In the case of San MarinoEstonia, double taxation shall be avoided in accordance with the provisions and subject to the limitations of the laws of Estonia (as follows it may be amended from time to time without changing the general principle hereof), as follows: a) Where where a resident of San Marino Estonia derives income which, in accordance with the provisions of this ConventionAgreement, may be has been taxed in BelgiumGuernsey, San Marino Estonia shall, subject to the provisions of sub-paragraphs subparagraph b) and c) paragraph 3, exempt such income from tax but may, nevertheless, in calculating the amount of tax on the remaining income of such resident, apply the same tax rate which would apply if the income in question were not exempt.tax; b) Where where a resident of San Marino Estonia derives income which, which in accordance with the provisions paragraph 2 of Articles 10 10, 11 and 11, 12 or paragraphs 1 and 2 of Article 16 may be taxed in BelgiumGuernsey, San Marino Estonia shall allow as a deduction from the tax on the income of that resident, resident an amount equal to the tax paid in BelgiumGuernsey. Such deduction shall not, however, exceed that part of the income tax, as computed before the deduction is given, which is attributable to the income arising which may be taxed in Belgium. c) Notwithstanding the provisions of sub-paragraph b), where a company which is a resident of San Marino has held at least 25 percent of the capital of a company which is a resident of Belgium paying dividends for at least 12 months prior to the decision to distribute the dividends, San Marino shall exempt from tax the dividends paid to the company which is a resident of San Marino by the company which is a resident of BelgiumGuernsey. 2. In the case of BelgiumGuernsey, double taxation shall be avoided as follows :follows. Subject to the provisions of the laws of Guernsey regarding the allowance as a credit against Guernsey tax of tax payable in a territory outside Guernsey (which shall not affect the general principle hereof): a) Where subject to the provisions of paragraph 3, where a resident of Belgium Guernsey derives incomeincome which, not being dividends, interest or royalties, which may be taxed in San Marino in accordance with the provisions of the Agreement, may be taxed in Estonia, Guernsey shall allow as a deduction from the tax payable in respect of that income, an amount equal to the income tax paid in Estonia; b) such deduction shall not, however, exceed that part of the income tax, as computed before deduction is given, which is attributable to the income which may be taxed in Estonia. 3. Where, in accordance with any provision of this ConventionAgreement, and which are taxed thereincome derived by a resident of a Party is not taxable in that Party, Belgium shall exempt such income from tax but mayParty may nevertheless, in calculating the amount of tax on the remaining income of that such resident, apply the rate of tax which would have been applicable if such income had not been exempted. However, in the case of a company which is a resident of Belgium, where the San Marino tax is less than 15 per cent of the net amount of the income referred to in this provision, Belgium shall not exempt that income, but reduce to a third the Belgian tax which is proportionally relating to that income, calculated as if that income were income from Belgian sources. b) Notwithstanding the provisions of sub-paragraph a) of this paragraph and any other provision of this Convention, Belgium shall, for the determination of the additional taxes established by Belgian municipalities and conurbations, take into account the earned income (revenus professionnels - beroepsinkomsten) that is exempted from tax in Belgium in accordance with sub-paragraph a) of this paragraph. These additional taxes shall be calculated on the tax which would be payable in Belgium if the earned income in question had been derived from Belgian sources. c) Dividends derived by a company which is a resident of Belgium from a company which is a resident of San Marino shall be exempt from the corporate income tax in Belgium under the conditions and within the limits provided for in Belgian law. d) Subject to the provisions of Belgian law regarding the deduction from Belgian tax of taxes paid abroad, where a resident of Belgium derives items of his aggregate income for Belgian tax purposes which are interest or royalties, the San Marino tax levied on that income shall be allowed as a credit against Belgian tax relating to such income. e) Where, in accordance with Belgian law, losses incurred by an enterprise carried on by a resident of Belgium in a permanent establishment situated in San Marino have been effectively deducted from the profits of that enterprise for its taxation in Belgium, the exemption provided for in sub-paragraph a) shall not apply in Belgium to the profits of other taxable periods attributable to that establishment to the extent that those profits have also been exempted from tax in San Marino by reason of compensation for the said losses.