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Pursuant to Legal Notice 97 of 2026 and Legal Notice 98 of 2026, published on 17 April 2026, amendments have been introduced to the Double Taxation Relief on Taxes on Income with Romania and the Double Taxation Relief on Taxes on Income with the Republic of San Marino.
These amendments specifically pertain to the operational aspects of the mutual agreement procedure (MAP) provisions within both tax treaties.
Changes to the Malta & Romania Double Tax Treaty
Legal Notice 97 of 2026 amends Article 26(2) of the Malta & Romania Double Tax Treaty by introducing an additional stipulation wherein the relevant competent authority shall endeavour to resolve the case through mutual agreement “if the objection appears to it to be justified.”
Both Contracting States are required to inform one another that the legal prerequisites for the amendment’s entry into force have been fulfilled. The revised Double Tax Treaty shall come into effect thirty days following the date of the later notification, the exact date of which will be published in the Government Gazette.
Moreover, the amended provisions will be applicable to income taxes derived during any calendar year or accounting period commencing on or after 1 January of the year immediately following the entry into force of the amended Malta & Romania Double Tax Treaty.
Changes to the Malta & San Marino Double Tax Treaty
Legal Notice 98 of 2026 amends Article 24(2) of the Malta & San Marino Double Tax Treaty through the deletion of a provision providing for the expiry of a MAP procedure at the end of the third year following the year in which the case was presented by the taxpayer.
Both Contracting States are also required to notify each other that the legal requirements for the entry into force of the amendment have been completed. The amended Double Tax Treaty will enter into force in both Contracting States on the date of the later notification, which date will be established by notice in the Government Gazette.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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