San Marino taxes resident individuals and companies on worldwide income and non-resident companies on San Marino-source income only, under a 2013 general framework law establishing a single income tax (IGR - Imposta Generale sui Redditi) for all income categories, applying uniformly to legal entities and individual-run companies alike. San Marino abolished bank secrecy and anonymous shareholding and now exchanges financial information under the OECD Common Reporting Standard.
The tax year generally follows the calendar year; tax declarations must be filed by 30 June each year with regard to income produced in the previous year, with the tax liability due by that same deadline (two advance installments are also required during the year).
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. 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.
A foreign company or individual that carries out economic activity in San Marino for more than 180 days in a calendar year is treated as a San Marino economic operator via permanent establishment and must obtain a Codice Operatore Economico (COE); below the 180-day threshold, a fixed-term activity licence suffices instead. Either way, a foreign applicant must appoint a locally resident agent who assumes the same rights and duties as a sole director, and operating beyond the 180-day threshold without COE registration exposes the operator to sanctions from the Ufficio Tributario.
No CFC-style attribution provision was found in San Marino's corporate tax legislation despite genuine search effort, including a specialist San Marino accounting/tax source describing the country's "group of companies" concept in detail (parent/subsidiary control and significant-influence relationships) - this defines consolidated reporting relationships rather than a CFC-style attribution mechanism, and no separate CFC regime was located. San Marino instead allows a foreign tax credit for tax definitively paid abroad on business income, capped at the San Marino tax proportionally attributable to that foreign-source income - a double-taxation relief mechanism, not an anti-deferral CFC rule.
No statutory thin capitalization ratio was identified in available sources.
San Marino classifies entities under its own domestic tax legislation rather than offering an elective check-the-box system, and no ATAD2-style anti-hybrid mismatch regime addressing double-deduction or deduction-without-inclusion outcomes has been identified, consistent with San Marino having no CFC-style attribution provision of its own. San Marino's 17% standard IGR rate sits above the 15% minimum effective tax rate threshold introduced under Italy's 2024 CFC simplification reform, meaning a San Marino subsidiary controlled by an Italian resident company is not automatically treated as a CFC subject to look-through taxation in Italy, provided the subsidiary conducts genuine economic activity with real substance.
No domestic FBAR-equivalent regime requires San Marino residents to separately disclose foreign financial accounts. San Marino is a CRS participating jurisdiction and exchanges financial account information with partner tax authorities as part of its move away from its earlier reputation as a secretive banking center. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of San Marino's own rules.
San Marino holding companies that have held their shares for at least 12 months pay tax on only 5% of dividends received from a company in a Double Tax Agreement partner country (after any foreign withholding tax), producing an effective tax rate of just 0.85% (17% x 5%) on such qualifying dividend income - a 95% participation exemption rather than a full 100% exemption.
San Marino allows a foreign tax credit for tax definitively paid abroad on business income, capped at the San Marino tax proportionally attributable to that foreign-source income, functioning as San Marino's principal double-taxation relief mechanism for income not otherwise covered by one of its approximately 20 bilateral tax treaties.
San Marino has approximately 20-23 double taxation treaties based on the OECD Model, including Italy (its most important treaty given San Marino is entirely surrounded by Italian territory), Switzerland, Austria, Germany, France, the UK, Singapore, the UAE, Qatar, Malta, Cyprus, and Seychelles, and has been actively expanding its network in recent years.