The Inland Revenue Board of Malaysia (IRBM) has published the synthesised text of the income tax treaty between Malaysia and San Marino as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI).
The synthesised text reflects the reservations and notifications submitted to the OECD Depositary by both Malaysia and San Marino. It is intended as a practical aid for readers who need to understand how the treaty operates after the MLI's modifications take effect, without having to cross-reference the original treaty text against the MLI instrument article by article.
The IRBM cautions that the synthesised text carries no independent legal authority. The authentic legal texts of the bilateral treaty and the MLI itself remain the instruments that govern in the event of any doubt or dispute.
Practitioners advising on Malaysia–San Marino cross-border arrangements should use the synthesised text as a working guide while retaining the original treaty and the MLI as the definitive legal references.