San Marino has published Council Decree No. 185 of 28 November 2024, which provides for the ratification of the pending protocol to the 2005 income tax treaty with Malta. The protocol, signed 1 April 2024, is the second to amend the treaty and provides for the deletion of 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." from subparagraph 2 of Article 24 (Mutual Agreement Procedure). The protocol will enter into force once the ratification instruments are exchanged and will apply from the...