By adopting the Action 15 minimum standard of the OECD BEPS project, San Marino allows for the simultaneous amendment of existing double taxation treaties to bring them into line with the BEPS principles by signing the OECD BEPS Multilateral Convention (MLI).
The Multilateral Convention was signed by the then Minister of Finance and Budget, Simone Celli, on behalf of San Marino on 7 June 2017. It was ratified on 20 February 2020 and entered into force on 1 July 2020 for San Marino.
The document to which the members of the Inclusive Framework, including San Marino, must adhere in order to adopt this standard is the Action 15 Final Report, Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, which was drafted in 2015 and followed up by the OECD FHTP Working Group.
