Table of Contents
- Executive Summary: Key Takeaways for 2025–2030
- Overview of San Marino’s Tax System
- Major Tax Law Amendments Effective in 2025
- Corporate Taxation: Rates, Incentives, and Compliance
- Personal Income Tax: Thresholds, Deductions, and Filing
- VAT, Indirect Taxes, and Customs Duties
- International Tax Treaties and Cross-Border Implications
- Compliance Obligations: Reporting, Audits, and Penalties
- Statistical Trends: Revenue, Compliance Rates, and Enforcement
- Future Outlook: Predicted Reforms and Strategic Considerations (2025–2030)
- Sources & References
Executive Summary: Key Takeaways for 2025–2030
San Marino’s tax law landscape for 2025–2030 is defined by ongoing modernization, a focus on international alignment, and the consolidation of compliance frameworks. Over recent years, the Republic has enacted significant reforms to enhance transparency, attract foreign investment, and align with European and international tax standards. The following key takeaways summarize the principal developments and outlook for tax law in San Marino in the upcoming years:
- Alignment with International Standards: San Marino continues to strengthen its anti-money laundering (AML) and anti-tax evasion frameworks to comply with OECD and EU requirements. Legislative amendments in recent years have targeted transparency, including automatic exchange of information and strengthened reporting obligations for both individuals and legal entities (Agenzia delle Entrate della Repubblica di San Marino).
- Corporate and Personal Taxation: The standard corporate income tax rate remains at 17%, while personal income tax rates are progressive, ranging from 9% to 35%. Recent measures have broadened the tax base, reduced loopholes, and improved digital filing systems for more efficient tax administration (Agenzia delle Entrate della Repubblica di San Marino).
- VAT and Indirect Taxes: San Marino maintains a unique VAT-equivalent system (Imposta Generale sui Servizi, or IGS), closely coordinated with Italy. Improvements in cross-border cooperation are expected as bilateral agreements evolve, reducing administrative friction for businesses operating in both jurisdictions (Segreteria di Stato per le Finanze e il Bilancio).
- Compliance & Enforcement: The government is intensifying tax audits, introducing digital tools for risk profiling, and leveraging data analytics for enforcement. Compliance is further encouraged by streamlined dispute resolution and appeals processes, as well as increased sanctions for non-compliance (Tribunale della Repubblica di San Marino).
- Key Statistics & Outlook: Tax revenues have shown moderate growth, with corporate tax receipts expected to remain stable as investment incentives take effect. The government projects steady economic growth and continued alignment with EU tax practices through 2030, positioning San Marino as a transparent, investor-friendly jurisdiction (Agenzia delle Entrate della Repubblica di San Marino).
Overall, San Marino’s tax law framework for 2025–2030 combines stability, compliance, and modernization, underpinning the Republic’s continued integration into the European economic landscape.
Overview of San Marino’s Tax System
San Marino’s tax system is characterized by a combination of progressive income taxation, corporate taxes, and indirect taxes, structured to support its microstate economy while complying with international standards on transparency and anti-money laundering. As of 2025, the tax regime continues to be governed by the main legislative framework, including Law No. 166/2013 (Income Tax Consolidated Law) and subsequent amendments, with oversight by the Ufficio Tributario (Tax Office).
For individuals, San Marino applies a progressive personal income tax (Imposta Generale sui Redditi – IGR) ranging from 9% to 35%, based on income brackets. There are various deductions and allowances for dependents and specific expenses. In 2024, the government implemented small adjustments to income brackets and deductions to offset inflationary pressures, a trend expected to continue into 2025 and beyond as the country aligns with EU economic standards despite not being a member state (Ufficio Tributario).
Corporate taxation is set at a flat rate of 17%, with certain incentives for innovative startups and investments in strategic sectors such as technology and tourism. Double taxation agreements (DTAs) have expanded in recent years, including with Italy and other key partners, providing greater clarity for cross-border activities. Recent legislative changes have clarified the tax residency criteria and introduced new compliance requirements for transfer pricing and country-by-country reporting, in line with international recommendations from the OECD Global Forum (Consiglio Grande e Generale).
San Marino levies a 17% indirect tax (Imposta sulle Importazioni – ISI), which functions as a customs-based system instead of a standard VAT. This regime is designed to prevent tax evasion and is closely monitored by customs and tax authorities. The country has further tightened anti-avoidance rules and enhanced digital reporting, with new IT infrastructure rolled out in 2023–2024 to improve compliance and data exchange with European authorities (Ufficio Tributario).
Key statistics from 2023 indicate that tax revenues accounted for approximately 23% of San Marino’s GDP, with ongoing efforts to increase compliance and broaden the tax base. Looking forward, the outlook for San Marino’s tax law includes continued modernization, digitalization, and efforts to harmonize with international tax norms, aiming to maintain competitiveness while ensuring fiscal sustainability (Banca Centrale della Repubblica di San Marino).
Major Tax Law Amendments Effective in 2025
San Marino has undertaken significant tax law reforms effective from January 1, 2025, aiming to align with evolving international standards and enhance fiscal transparency. These amendments emerge from the Republic’s ongoing efforts to strengthen its compliance with European Union (EU) directives and recommendations from the Organisation for Economic Co-operation and Development (OECD). The changes target corporate income tax, personal income tax, and value-added tax (VAT), with a particular focus on anti-avoidance measures and digital economy compliance.
- Corporate Income Tax Reforms: The standard corporate income tax rate remains at 17%, but new rules have been introduced regarding the deductibility of cross-border expenses and the use of tax losses. The amendments restrict the carryforward of tax losses to 70% of annual taxable income for each fiscal year, effective from 2025. Furthermore, stricter documentation requirements are now in place for the deduction of costs associated with transactions involving non-cooperative jurisdictions, aligning with international anti-base erosion initiatives (Secretariat of State for Finance and Budget of San Marino).
- Personal Income Tax and Withholding: The 2025 amendments introduce a revised progressive scale for personal income tax, with updated brackets to reflect inflation adjustments and cost-of-living increases. Additionally, new withholding obligations apply to payments made to certain categories of non-residents, mirroring EU best practices and increasing tax certainty for cross-border workers (Tax Office of San Marino).
- VAT and Digital Economy Measures: In line with the EU VAT e-commerce package, San Marino has extended VAT obligations to non-resident providers of digital services to San Marino consumers. The amendments establish simplified registration and reporting mechanisms, ensuring compliance for foreign digital platforms and service providers. This aims to tackle VAT leakage and create a level playing field for local businesses (Tax Office of San Marino – VAT Section).
- Anti-Avoidance and Transparency: The 2025 reforms implement the latest OECD recommendations on anti-avoidance, including enhanced transfer pricing documentation and mandatory disclosure rules for certain cross-border arrangements. San Marino has also expanded its automatic exchange of information agreements, further reinforcing its commitment to transparency and combating tax evasion (Secretariat of State for Finance and Budget of San Marino).
Looking ahead, these amendments are expected to improve San Marino’s tax compliance landscape and foster international cooperation, while also supporting the country’s efforts to remain off EU and OECD tax blacklists. Early feedback from stakeholders suggests that the new measures will require businesses and individuals to enhance their compliance systems, particularly in cross-border contexts. San Marino authorities have indicated that further minor adjustments may follow as part of their ongoing fiscal modernization agenda.
Corporate Taxation: Rates, Incentives, and Compliance
San Marino’s corporate tax regime remains a central element of its fiscal framework, designed to maintain competitiveness while ensuring compliance with evolving international standards. As of 2025, the standard corporate income tax rate is set at 17%, with certain reductions and incentives available for qualifying entities. These rates reflect ongoing government efforts to align with European norms while preserving San Marino’s attractiveness to foreign investors.
The corporate tax base includes worldwide income for resident companies and San Marino–source income for non-residents. Notably, tax incentives continue to play a significant role. Newly established enterprises may benefit from a 50% reduction of the standard rate for the first five years of operation, especially if they operate in sectors prioritized by national economic policy, such as technology, tourism, and innovative industries. Additionally, enterprises investing in research and development can access further tax credits and deductions, fostering an environment conducive to innovation and economic diversification (Agenzia delle Entrate della Repubblica di San Marino).
Compliance requirements have tightened in recent years, reflecting San Marino’s commitments to anti-money laundering (AML) and base erosion and profit shifting (BEPS) initiatives. Companies are required to maintain accurate accounting records, submit annual financial statements, and file tax returns electronically by the end of the fifth month following the close of the fiscal year. Transfer pricing regulations have also been strengthened, mandating documentation to substantiate the arm’s length nature of intra-group transactions. Penalties for non-compliance include fines, interest charges, and, in severe cases, criminal liability for tax evasion (Consiglio Grande e Generale).
Key statistics indicate that corporate tax revenues constituted approximately 19% of total tax receipts in 2024, with a projected modest increase in 2025 due to expanded compliance measures and economic recovery initiatives post-pandemic (Banca Centrale della Repubblica di San Marino). The tax authority continues to implement digital tools for monitoring compliance and streamlining audits, which is expected to further enhance revenue collection in the coming years.
Looking ahead, San Marino is anticipated to continue refining its corporate tax laws to attract investment while strengthening its international reputation for transparency. Ongoing dialogue with European and international bodies suggests further harmonization with global tax standards, particularly concerning transparency, beneficial ownership disclosure, and tax information exchange. These developments position San Marino as a compliant, competitive jurisdiction for corporate activity in the heart of Europe.
Personal Income Tax: Thresholds, Deductions, and Filing
San Marino’s personal income tax (Imposta Generale sui Redditi delle Persone Fisiche, or IGREP) is governed by Law No. 166 of December 16, 2013, and subsequent amendments. For the 2025 tax year, the IGREP continues to apply progressive rates, accompanying thresholds and deductions that reflect the republic’s commitment to fiscal transparency and alignment with international standards.
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Tax Rates and Thresholds:
The IGREP is structured in progressive brackets. For 2025, the rates are expected to remain as follows:- Up to €10,000: 9%
- €10,001 – €18,000: 13%
- €18,001 – €28,000: 17%
- €28,001 – €50,000: 21%
- Over €50,000: 35%
These brackets have remained stable in recent years, though the government regularly reviews them as part of broader fiscal policy adjustments.
(Consiglio Grande e Generale) -
Deductions and Allowances:
Taxpayers can claim a standard deduction of €1,000, with further deductions available for dependent family members, mortgage interest, education expenses, and certain medical costs. Recent reforms have streamlined eligibility for these deductions, emphasizing documentation and compliance.
(Ufficio Tributario) -
Filing Requirements and Compliance:
Residents and certain non-residents must file annual returns by June 30 of the year following the tax year. E-filing through the online portal has become mandatory for most individuals, with support channels provided for first-time filers. Withholding at source by employers is standard, but an annual return is required to reconcile additional income, deductions, or credits.
(Ufficio Tributario) -
Key Statistics:
In 2023, personal income tax accounted for approximately 15% of San Marino’s total tax revenue, with over 16,000 individual returns filed. Compliance rates remain high, reflecting robust enforcement and public awareness campaigns by the tax authority.
(Ufficio di Statistica) -
Outlook (2025 and Beyond):
While no major changes to personal income tax rates or thresholds are planned for 2025, the government is considering digitalization initiatives to improve taxpayer services and fraud detection. Ongoing alignment with EU anti-avoidance standards may prompt minor compliance adjustments in the coming years.
(Ufficio Tributario)
VAT, Indirect Taxes, and Customs Duties
San Marino’s framework for VAT, indirect taxes, and customs duties continues to evolve in response to international standards and economic developments within the European context, despite the country’s non-EU status. The Imposta Generale sui Servizi (IGS), San Marino’s equivalent to VAT, remains central to indirect taxation and is governed by Law No. 71/2010 and subsequent amendments. As of 2025, the standard IGS rate is 17%, with certain reduced rates and exemptions for specific goods and services, aligning with efforts to balance fiscal requirements and competitiveness for local businesses.
San Marino’s customs regime is closely integrated with the European Union under the Customs Union Agreement signed in 1991 and updated in subsequent protocols. Goods imported from and exported to EU countries benefit from simplified customs procedures and tariff-free access, provided they comply with rules of origin and documentation requirements. This arrangement requires San Marino to mirror key aspects of the EU Customs Code, including the electronic submission of customs declarations and adherence to technical and safety standards for goods. In 2024, the government announced further digitalization of customs processes, aiming for full implementation by 2026, to increase transparency and reduce administrative burdens for traders.
Recent years have seen reinforced compliance measures, particularly in combating tax evasion and facilitating cross-border cooperation. The San Marino Tax Office (Ufficio Tributario) has expanded its audit capabilities for indirect tax compliance, leveraging data-sharing agreements with the EU and other countries. Notably, Law No. 115/2017 introduced stricter rules for VAT registration, invoicing, and reporting, with penalties for non-compliance ranging from monetary fines to business suspension. In 2023, the Tax Office reported a 9% increase in VAT-related audits, resulting in a significant recovery of unpaid taxes.
Key statistics from the Ufficio Tributario indicate that indirect tax revenues accounted for approximately 41% of total tax intake in 2023, reflecting the importance of these levies to public finances. Customs duties remain a modest source of revenue due to the EU agreement but are crucial for regulating non-EU trade and enforcing product safety.
Looking ahead to 2025 and beyond, San Marino is expected to further harmonize its indirect tax and customs frameworks with EU best practices, particularly in digitalization, compliance oversight, and transparency. Ongoing legislative updates and closer administrative cooperation with EU authorities will likely enhance revenue collection and reduce the risk of fraud, supporting the Republic’s fiscal sustainability and international integration.
International Tax Treaties and Cross-Border Implications
San Marino, as a microstate surrounded by Italy, has strategically modernized its tax framework to enhance international cooperation and compliance. Recent years have seen a significant expansion of San Marino’s network of international tax treaties, specifically aimed at preventing double taxation and aligning with global standards against tax evasion.
As of 2025, San Marino has concluded more than 20 double taxation agreements (DTAs) with countries including Italy, Malta, Liechtenstein, and Hungary. These treaties are designed to facilitate cross-border business and investment, provide clarity on tax residency, and allocate taxing rights between jurisdictions. The agreements generally follow the OECD Model Tax Convention, ensuring provisions for the exchange of information and mutual assistance in tax collection. These efforts are part of San Marino’s ongoing commitment to transparency and international best practices, particularly since its removal from the OECD grey list in 2014.
The 2019 DTA with Italy, San Marino’s most significant economic partner, remains central to cross-border taxation. It covers income and capital taxes, addresses residency rules, and includes mechanisms for the avoidance of double taxation. The treaty also mandates administrative cooperation on tax matters, allowing for automatic exchange of financial account information under the Common Reporting Standard (CRS). In 2023, San Marino further enhanced its anti-abuse provisions and compliance mechanisms in line with BEPS (Base Erosion and Profit Shifting) recommendations from the OECD and EU directives.
Compliance with these international obligations is overseen by the San Marino Tax Office. Businesses with cross-border operations are required to ensure proper documentation of transfer pricing, substance, and beneficial ownership to avoid penalties. San Marino also participates in the automatic exchange of information under the CRS, exchanging data with over 100 jurisdictions as of 2025. Authorities have intensified scrutiny of cross-border structures, particularly focusing on beneficial ownership transparency and related-party transactions.
Key statistics reflect growing cross-border activity: in 2024, over 30% of San Marino’s corporate tax revenue derived from entities engaged in international trade or investment. The Ministry of Finance projects a steady increase in inbound and outbound investment flows, supported by the reduction of withholding taxes and simplified procedures under new and renegotiated treaties.
Looking ahead, San Marino is expected to continue expanding its treaty network, with ongoing negotiations with several EU and non-EU countries. Regulatory alignment with EU anti-tax avoidance directives and further digitization of compliance processes are anticipated. These developments will reinforce legal certainty for investors and bolster San Marino’s position as a reputable, compliant jurisdiction for cross-border business.
- Ministry of Foreign Affairs, San Marino
- Ministry of Finance, San Marino
- Agenzia delle Dogane e dei Monopoli (Italy)
- Organisation for Economic Co-operation and Development (OECD)
Compliance Obligations: Reporting, Audits, and Penalties
San Marino’s tax compliance landscape in 2025 is characterized by robust reporting obligations, regular audit procedures, and a structured penalties regime, reflecting the country’s ongoing commitment to transparency and alignment with international standards. The principal legal framework governing compliance includes Law no. 166/2013 and subsequent amendments, which set forth obligations for individuals, businesses, and other entities subject to San Marino taxation.
Reporting Obligations in San Marino require taxpayers—including corporations, self-employed professionals, and individuals with income above specified thresholds—to submit annual tax returns declaring all sources of income, assets, and relevant deductions. Electronic filing is mandatory for most categories, and the deadline for submission typically falls within the first half of the calendar year following the tax period. For 2025, enhancements to the digital tax portal have streamlined both filing and payment processes, and the introduction of pre-filled returns for certain individual taxpayers is anticipated to increase compliance rates (Ufficio Tributario San Marino).
San Marino is committed to international tax cooperation, participating in the OECD’s Common Reporting Standard (CRS) for automatic exchange of financial account information. Financial institutions are required to identify and report accounts held by non-residents, with reporting deadlines generally set for mid-year. Failure to comply can result in administrative sanctions and increased scrutiny for both institutions and account holders (Banca Centrale della Repubblica di San Marino).
Audits are conducted by the Ufficio Tributario, which applies risk-based criteria to select taxpayers for review. The audit process may include desk reviews, requests for supplementary documentation, and on-site inspections. Sectors frequently targeted include cross-border transactions, financial services, and high-net-worth individuals, reflecting San Marino’s efforts to prevent tax evasion and money laundering. Recent data indicate that audit rates have increased modestly year-on-year, with approximately 7% of corporate taxpayers undergoing some form of fiscal inspection in 2024 (Ufficio Tributario San Marino).
Penalties for non-compliance are tiered according to the nature and gravity of the infraction. Administrative fines apply for late filing, underreporting, or non-payment, ranging from €250 to 30% of the undeclared or unpaid tax amount. More severe violations, such as deliberate tax evasion or fraudulent declarations, can trigger criminal prosecution and higher financial sanctions. In 2025, enforcement is expected to intensify, particularly for cross-border infractions and failures to comply with international information-sharing obligations (Tribunale della Repubblica di San Marino).
Looking ahead, the outlook for tax compliance in San Marino suggests a continued emphasis on digitalization, automation, and international cooperation, with further regulatory updates expected to reinforce transparency and accountability over the next few years.
Statistical Trends: Revenue, Compliance Rates, and Enforcement
San Marino, while not a member of the European Union, has made significant strides in aligning its tax framework with international standards, particularly in the wake of increased global scrutiny on tax transparency. As of 2025, the Republic’s tax law continues to be shaped by commitments to the OECD and the European Union, focusing on anti-money laundering, information exchange, and combating tax evasion. These reforms have influenced key statistical trends in revenue, compliance rates, and enforcement activities.
- Tax Revenue Trends: In the last five years, San Marino has seen a steady increase in tax revenues, attributed largely to improved compliance mechanisms and the broadening of the tax base. According to the latest annual financial report, tax revenues reached approximately €390 million in 2023, representing a 3.8% year-on-year growth, with projections for 2025 targeting a continued moderate rise as economic activity recovers post-pandemic and digitalization enhances tax collection (Consiglio Grande e Generale).
- Compliance Rates: The adoption of digital tax reporting platforms and electronic invoicing (FatturaPA) has substantially improved compliance rates among businesses and individuals. The Tax Office reported that over 94% of businesses filed tax declarations electronically in 2024, up from 89% in 2022. Personal income tax compliance has also increased, with voluntary disclosures and strengthened audit procedures contributing to a declared compliance rate above 91% for fiscal year 2024 (Ufficio Tributario).
- Enforcement and Penalties: Enforcement actions have intensified, particularly regarding VAT fraud and cross-border tax evasion, reflecting San Marino’s adherence to international standards. The Financial Intelligence Agency and Tax Police conducted 117 targeted inspections in 2023, resulting in assessments and penalties totaling €7.2 million. San Marino’s authorities anticipate further increases in enforcement activity through 2025 as resources are allocated to risk-based audits and international cooperation agreements (Agenzia di Informazione Finanziaria).
- Outlook: Looking ahead, San Marino’s tax authorities are expected to continue investing in digitalization and cross-border information sharing, with a focus on further improving compliance rates and revenue collection. Legislative amendments in 2025 will likely target tax base erosion and profit shifting, as well as enhanced due diligence for high-net-worth individuals and corporate entities.
Future Outlook: Predicted Reforms and Strategic Considerations (2025–2030)
San Marino’s tax law is poised for significant evolution between 2025 and 2030 as the Republic continues to pursue fiscal modernization and align with international standards. As a microstate situated within the European context, San Marino has taken proactive measures in recent years to enhance tax transparency, anti-money laundering protocols, and cross-border cooperation, responding to recommendations from international bodies and adapting to economic pressures.
Key areas of anticipated reform include further adjustments to corporate and personal income taxation, increased digitization of tax administration, and strengthened compliance mechanisms. In 2025, San Marino is expected to refine its corporate tax regime—currently characterized by a standard rate of 17%—to maintain competitiveness while ensuring compliance with the European Union’s anti-tax avoidance directives and the OECD’s BEPS framework (Agenzia per le Entrate della Repubblica di San Marino). This may include targeted incentives for innovative sectors, start-ups, and green investments, reflecting ongoing governmental consultations.
On the individual side, the progressive personal income tax system, which presently ranges from 9% to 35%, may undergo recalibration to broaden the tax base and enhance fairness. The government is also expected to review the withholding tax regime for non-residents to further align with international best practices, in response to bilateral agreements and evolving EU expectations (Consiglio Grande e Generale della Repubblica di San Marino).
Digitization remains a strategic priority through the ongoing rollout of e-filing and electronic invoicing, aimed at reducing administrative burdens and improving compliance. The recent adoption of the “FatturaPA” electronic invoicing framework is anticipated to yield higher transparency and facilitate audit procedures (Agenzia per le Entrate della Repubblica di San Marino).
Recent statistics reflect San Marino’s efforts to enhance tax compliance: tax revenue as a share of GDP reached approximately 17.1% in 2023, with year-on-year growth projected as administrative reforms mature. Authorities anticipate this share will rise modestly by 2030, driven by improved collection and broadening of the tax base (Ufficio Informatica, Tecnologia, Dati e Statistica).
Strategically, San Marino’s tax policy outlook for 2025–2030 emphasizes balancing fiscal sustainability, international credibility, and economic growth. Ongoing dialogue with international partners, continuous monitoring of compliance standards, and agile legislative updates will likely define San Marino’s tax landscape in the coming years.
