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Luxembourg: Amending protocols to income tax treaties with Georgia and San Marino approved; tax treaty with Montenegro effective October 1, 2025

The protocols move forward for further legislative steps.

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January 7, 2026

The Luxembourg Council of Government in late October 2025 approved the amending protocols to the following:

  • Luxembourg-Georgia Income and Capital Tax Treaty (2007). The protocol, signed on July 3, 2025, and ratified by Georgia on November 12, 2025, now moves forward for further legislative steps in Luxembourg before being ratified.
  • Luxembourg-San Marino Income and Capital Tax Treaty (2006), as amended by the 2009 protocol. The protocol, signed on May 14, 2025, now moves forward to the next legislative steps.

In addition, the tax treaty between Luxembourg and Montenegro became effective on October 1, 2025. It covers Luxembourg's individual, corporate, capital, and communal trade taxes, and Montenegro's corporate profit and personal income taxes. It generally applies as of January 1, 2026, for withholding tax and other taxes.


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

Sandrine Degreve | sandrine.degreve@kpmg.lu

Celine Besch | celine.besch@kpmg.lu

Driss Delubac | driss.delubac@kpmg.lu

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