Tax Treaties in San Marino

San Marino has a limited network of double taxation agreements (DTAs). The country's primary tax treaty is with Italy, though it has also entered into tax information exchange agreements with several other jurisdictions.

Double Taxation Agreements

San Marino has concluded double taxation agreements with a limited number of countries. The most significant treaty is with Italy, given the geographic proximity and economic integration between the two countries.

Treaty with Italy

The San Marino-Italy double taxation treaty covers:

• Exchange of tax information between authorities
• Mechanisms to resolve double taxation disputes
• Reduced withholding tax rates for cross-border payments
• Permanent establishment definition
• Residency tie-breaker rules for individuals and companies

Withholding Tax Rates

San Marino's domestic withholding tax rates for payments to non-residents are:

Transfer Pricing

San Marino follows the arm's length principle for related-party transactions. Transfer pricing documentation is recommended for:

• Transactions exceeding certain thresholds with related parties
• Intellectual property transactions
• Financing arrangements

Foreign Tax Credit

Resident taxpayers can claim a foreign tax credit for taxes paid abroad on foreign-source income. The credit is limited to the San Marino tax payable on that income.

Exchange of Information

San Marino participates in international tax cooperation and has signed Tax Information Exchange Agreements (TIEAs) with several countries. San Marino has committed to OECD standards on transparency and exchange of information.

Inbound Investment

Foreign investors in San Marino are subject to:

• CIT on San Marino-source income at 17%
• Withholding taxes on distributions
• No exchange controls

Outbound Investment

San Marino residents investing abroad are taxed on their worldwide income, with foreign tax credits available.