Luxembourg's Council of State Approves Pending Protocol to Tax Treaty with San Marino

On 20 January 2026, Luxembourg's Council of State approved the ratification of the pending protocol to the 2006 income and capital tax treaty with San Marino. The protocol, signed 14 May 2025, amends paragraph 2 of Article 25 (Mutual Agreement Procedure) with the removal of the sentence "The mutual agreement procedure shall expire by the end of the third year following that in which the case wa…