The income tax treaty between Portugal and San Marino entered into force on 3 December 2015. The treaty, signed 18 November 2010, is the first of its kind between the two countries. Taxes Covered The treaty covers Portuguese personal income tax, corporate income tax, and local surtax on corporate income tax. It covers San Marino general income tax on individuals and on bodies corporate and proprietorships. Withholding Tax Rates Dividends - 10% if the beneficial owner is a company directly holding at least 25% of the paying company's capital, otherwise 15% Interest - 10% Royalties - 10% Capital Gains The...