An amending protocol to the Georgia–San Marino Income and Capital Tax Treaty has entered into force, removing the previous three-year limit on mutual agreement procedures and aligning the treaty with the OECD’s 2017 Model Tax Convention.
The amending protocol to the Georgia–San Marino Income and Capital Tax Treaty (2012), signed on 17 October 2025, entered into force on 28 August 2026.
The protocol removes the previous three-year time limit for mutual agreement procedures and updates the Georgia–San Marino tax treaty to align with the OECD’s 2017 Model Tax Convention. As the first amendment to the treaty, it aims to prevent double taxation and combat fiscal evasion involving income and capital taxes.
The protocol generally applies from 1 January 2027 and amends Article 25(2) on the Mutual Agreement Procedure by removing the provision that limited the procedure to the end of the third year following the year in which the taxpayer’s case was presented.
Earlier, San Marino ratified an amending protocol to its income and capital tax treaty with Georgia, pursuant to Council Decree No. 63, published on 30 April 2026.
