San Marino has published Council Decree No. 119 of 26 September 2025, which provides for the ratification of the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI). San Marino signed the STTR MLI on 19 September 2024, which provides for the implementation of the STTR in bilateral tax treaties. The STTR allows jurisdictions to "tax back" w…