San Marino has ratified an amending protocol updating its 2012 income and capital tax treaty with Georgia, removing a three-year time limit on mutual agreement procedures and aligning the treaty with the OECD's 2017 Model Tax Convention.
San Marino has ratified an amending protocol that updates its income and capital tax treaty with Georgia, according to Council Decree No. 63 published on 30 April 2026.
The protocol, which was signed on 17 October 2025, introduces a significant change to Article 25 covering the Mutual Agreement Procedure. The amendment removes the previous time restriction, stating that mutual agreement procedures must conclude within three years of a taxpayer presenting their case.
The protocol is also 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.
San Marino’s Grand and General Council gave its approval to the protocol on 22 April 2026 through Resolution No. 20. The updated provisions will become effective once both countries exchange their ratification instruments. Following this exchange, the protocol will apply from 1 January of the following year.
The original tax treaty between Georgia and San Marino was established in 2012. This recent protocol aims to modernise dispute resolution mechanisms between the two nations by eliminating arbitrary time constraints on resolving taxpayer cases.
Earlier, Georgia’s Parliament approved the ratification of the protocol amending the 2012 Income and Capital Tax Treaty with San Marino on 26 November 2025.
