Luxembourg has confirmed that a protocol amending its income and capital tax treaty with San Marino took effect on 16 September 2026, removing the three-year time limit on the mutual agreement procedure.
Luxembourg’s amending protocol to the 2006 income and capital tax treaty with San Marino entered into force on 16 September 2026, according to a notice published in the Official Gazette on 23 October 2026.
Signed on 14 May 2025, the protocol amends paragraph 2 of Article 25 (Mutual Agreement Procedure) by deleting the sentence “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 amendment applies from 1 January 2027.
