San Marino Ratifies Pending Protocol to Tax Treaty with Georgia

San Marino has published Council Decree No. 63 of 30 April 2026, which provides for the ratification of the pending protocol to the 2012 income and capital tax treaty with Georgia. The protocol, signed 17 October 2025, amends Article 25 (Mutual Agreement Procedure) with the removal of the provision that "The mutual agreement procedure shall expire by the end of the third year following that in which the case was presented by the taxpayer." The protocol will enter into force once the ratifica…