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Georgia: Protocols to income and capital tax treaties with San Marino and Luxembourg ratified

Recent tax treaty developments

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december 4, 2025

The Ministry of Finance on October 18, 2025, announced the signing of an amending protocol to the 2012 Georgia–San Marino Income and Capital Tax Treaty, which brings the treaty in line with the 2017 OECD model. The protocol was submitted to Parliament on November 3, 2025, was ratified on November 26, 2025, and was published on November 28, 2025.

In addition, the amending protocol to the Georgia–Luxembourg Income and Capital Tax Treaty (2007) related to the exchange of information (Article 27) was signed on July 3, 2025, was submitted to Parliament for ratification on September 29, 2025, was ratified on November 11, 2025, and was published on November 13, 2025.
 

For more information, contact a KPMG tax professional in Georgia:

Ana Mardaleishvili | amardaleishvili@kpmg.com

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