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San Marino Introduces New MAP Provisions

07 December 2021

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Approved Changes

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San Marino

San Marino has published Law No. 192 of 26 November 2021 in the Official Gazette, which provides for the introduction of new measures for Mutual Agreement Procedures (MAP) under tax treaties in line with international best practices and BEPS Action 14 (Dispute Resolution). The measures of the law cover various issues, including: Instances where MAP may be applied for, with applications for MAP to be generally submitted within three years from the date of the action that has or will result in taxation not in accordance with a tax treaty; Preliminary procedures, rules for accepting or rejecting a MAP application,...