Corporate Tax in San Marino

San Marino's corporate tax system features a standard rate of 17% under the Imposta sul Reddito delle Società. There is no minimum tax requirement. The tax framework is administered by the San Marino tax authorities.

Corporate Income Tax Rate

The standard corporate income tax rate in San Marino is 17% of taxable profits. This applies to all resident companies and foreign companies with a permanent establishment in San Marino. There is no minimum tax.

Taxable Income

Taxable income is calculated as gross revenue minus allowable deductions. The tax year in San Marino follows the calendar year (January 1 to December 31). Companies must maintain proper accounting records.

Deductible Expenses

• Operating expenses directly related to business activities
• Depreciation of fixed assets (straight-line method)
• Interest expense
• Rent and lease payments
• Employee salaries and social security contributions
• Professional fees and consulting costs
• Research and development expenses
• Marketing and advertising costs
• Insurance premiums

Non-Deductible Expenses

• Fines and penalties
• Dividends distributed
• Capital expenditures (must be depreciated)
• Personal expenses of shareholders
• Donations to non-approved organizations

Tax Incentives

San Marino offers several tax incentives to encourage investment:

• Innovation Credits: Tax credits for research and development activities
• Investment Incentives: Reduced rates for qualifying investments in priority sectors
• Accelerated Depreciation: Available for certain qualifying assets
• Carryforward of Losses: Tax losses can be carried forward for up to 5 years

Filing Requirements

• Annual Tax Return: Due by June 30 following the tax year
• Monthly Withholding Tax: Due by the 15th of the following month
• Annual Financial Statements: Must be filed with the tax return
• Transfer Pricing Documentation: Required for related-party transactions

Payment of Tax

Corporate tax is payable in two ways:

• Advance Payments: Quarterly installments based on the previous year's tax liability
• Balance Payment: Any remaining tax due is payable upon filing the annual return

Withholding Taxes

Companies are required to withhold tax on certain payments:

• Dividends to residents: 0%
• Dividends to non-residents: 10%
• Interest: 0%
• Royalties: 10%

International Taxation

San Marino taxes residents on their worldwide income. Foreign tax credits are available for taxes paid abroad on foreign-source income. San Marino has double taxation agreements mainly with Italy.