The amending protocol to the 2012 income and capital tax treaty between Georgia and San Marino entered into force on 28 August 2026. The protocol, signed 17 October 2025, amends Article 25 (Mutual Agreement Procedure) by removing the provision that "The mutual agreement procedure shall expire by the end of the third year following that in which the case was presented by the taxpayer." The protocol applies from 1 January 2027.