San Marino has published Council Decree No. 120 of 26 September 2025, which provides for the ratification of the pending protocol to the 2006 income and capital tax treaty with Luxembourg. 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 was presented by the tax payer." It will enter into force once the rati…