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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).

June 15, 2026

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

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