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Update - Protocol to Tax Treaty between Malta and San Marino

14 November 2024

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Treaty Development

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Malta-San Marino

The amending protocol to the 2005 income tax treaty between Malta and San Marino was signed on 1 April 2024. The protocol 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 date of its entry into force.