San Marino

Southern Europe · SM · 22 treaties

Tax profile

What makes you a tax resident — and how hard it is to stop being one.

• registered as fiscally resident in the residents register of San Marino (anagrafe tributaria) following grant of residence permit by the Gendarmeria / Congress of State
• holding a residence permit and having a home (owned or rented) in the territory of San Marino for ordinary residence
• non‑domiciled tax residence: temporary stay in qualifying San Marino hotels for a minimum of 30 days and a maximum of 150 days in a calendar year, combined with payment of the €10,000 annual substitute tax and satisfaction of integrity conditions

Tax residence is status‑based (registration and specific special‑regime permits) rather than citizenship‑ or domicile‑based, so ceasing residence or letting a non‑domiciled or special permit lapse generally ends San Marino tax residence once you leave and de‑register, with no multi‑year tail rules. There is no indication in official or professional guidance of citizenship‑based taxation, exit tax, or long look‑back tests that would keep former residents taxable after departure.

Source: Toccaceli Bronzetti (quoting San Marino non‑domiciled tax residence rules)

Tax treaty network (22)

In-force double-tax treaty partners. Treaty-reduced withholding (dividends / interest / royalties) shown where the official source publishes a rate; otherwise the country's statutory rate applies unless the treaty text provides a reduction.