The protocol amends the Georgia–San Marino tax treaty, marking the first modification to the original agreement. 

Georgia’s Parliament has approved the ratification of the protocol amending the 2012 Income and Capital Tax Treaty with San Marino on 26 November 2025.

The protocol, initially signed on 17 October 2025, amends Article 25 of the treaty, which concerns the Mutual Agreement Procedure, including the removal of the previous expiration timeline.

The protocol is the first modification to the original agreement and aims to prevent double taxation and curb fiscal evasion on income and capital taxes between Georgia and San Marino. The amendment also seeks to align the existing treaty with the OECD’s 2017 Model Tax Convention.

The protocol will officially enter into force after the exchange of ratification instruments.

Earlier, officials from Georgia and San Marino signed an amending protocol amending their 2012 income and capital tax treaty on 17 October 2025.