Malta: Protocol to tax treaty with San Marino enters into force
The key change eliminates the three-year deadline for resolving cases through the mutual agreement procedure (MAP).
The governments of Malta and San Marino brought into force (April 22, 2026) an amending protocol to the 2005 income tax treaty.
The key change eliminates the three-year deadline for resolving cases through the mutual agreement procedure (MAP), which may improve flexibility in competent authority dispute resolution.
For more information, contact a KPMG tax professional in Malta:
John Ellul Sullivan | johnellulsullivan@kpmg.com.mt
Lisa Zarb Mizzi | lisazarbmizzi@kpmg.com.mt