Luxembourg has moved closer to ratifying the amended tax treaty with San Marino, with the Council of State approving the protocol in January 2026. 

Luxembourg’s Council of State has approved the ratification of the amending protocol to the 2006 income and capital tax treaty with San Marino on 20 January 2026.

The two countries signed an amending protocol to their 2006 tax treaty on 14 May 2025, marking the second revision to the agreement following an earlier update in 2009. The revised treaty is intended to prevent double taxation and tax evasion.

The amended agreement will enter into force once both countries exchange their instruments of ratification and will apply from 1 January of the following year.

Earlier, Luxembourg’s Government Council approved protocols updating the tax treaty with San Marino on 31 October 2025.