San Marino & Malta Double Tax Treaty


The Double Taxation Relief Treaty between Malta and San Marino was signed in Valletta on 3 May 2005 and is currently in force since 19 July 2005. The main features of the Double Tax Treaty Malta San Marino are as follows:

San Marino Withholding Taxes

Dividend Income

The Double Tax Treaty Malta San Marino states that the maximum San Marino withholding tax on dividends distributed by a San Marino resident company to a Maltese resident company where the Maltese resident company holds at least 25% of the share capital of the San Marino resident company is 5%. In all other cases, the maximum San Marino withholding tax is 10%.

Interest Income

The Double Tax Treaty Malta San Marino states that there is no San Marino withholding tax on interest paid by a San Marino resident to a Maltese resident owner of the interest income.

Royalty Income

The Double Tax Treaty Malta San Marino states that there is no San Marino withholding tax on royalties paid by a San Marino resident to a Maltese resident beneficial owner of the royalty income.

Other Income

The Double Tax Treaty Malta San Marino states that pensions and other similar remuneration from San Marino sources to a Maltese resident individual may only be taxed in Malta.

However, this does not apply for pensions paid under provisions of the social security legislation of San Marino, which are taxable in San Marino only.

Please contact us should you require any more information on the Malta San Marino Double Tax Treaty and the unique tax planning opportunities that may arise. You can email us on enquiries@papilioservices.com or call us directly on +356 2258 2000.


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