San Marino has emerged as a trailblazer in international tax reform by becoming the first jurisdiction to deposit its ratification instrument for the multilateral Convention implementing the Subject to Tax Rule under the OECD’s BEPS framework. This significant milestone marks San Marino’s commitment to strengthening global tax standards and combating harmful tax practices. By activating this mechanism, San Marino not only enhances its tax transparency but also helps to ensure that income generated within its borders is taxed in a manner consistent with international norms.

The implementation of the Subject to Tax Rule introduces targeted protection against treaty abuse by enabling jurisdictions to deny treaty…