17% flat (Imposta Generale sui Redditi - IGR, corporate); new businesses may qualify for an effective 8.5% rate for 5 years, and qualifying innovative startups for 0-8%.
Progressive, 9% to 35% across eight brackets (IGR - Imposta Generale sui Redditi, individual).
No traditional VAT; a single-stage General Consumption Tax (Monofase / IGC) applies at 17% on imports, with reduced rates of 6% and 2% for specified categories - businesses can generally recover Monofase paid on imports, so the effective incidence falls on end consumers.
An individual is resident for tax purposes if domiciled or habitually resident in San Marino, or present 183 days or more in a calendar year, confirmed via multiple independent sources. A company is resident if incorporated in San Marino or centrally managed and controlled there. Residents are taxed on worldwide income; non-residents are taxed on San Marino-source income only.
No Controlled Foreign Company regime was identified in available sources this session. This is a genuine gap rather than a confirmed absence.
No statutory thin capitalization ratio was identified in available sources.
No domestic FBAR/Form 8938-equivalent requiring San Marino residents to self-report their own foreign accounts was identified. Institutional-level CRS/FATCA participation status was not independently confirmed this session. Separately and independently of local law, US citizens and Green Card holders with San Marino accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of local requirements.
San Marino has approximately 20 double taxation treaties and has been actively expanding its network in recent years, confirmed via TaxAtlas, as part of a broader modernization effort moving away from the country's earlier reputation as a secretive banking center. A specific named-partner list was not compiled this session.