# San Marino

 Country code: SM · Currency: EUR · Language: Italian

**Pros**
- Competitive corporate tax rates and specific incentives for innovative startups to minimize fiscal burden
- Exceptional personal safety and low crime rates for the protection of private property
- High degree of political stability and direct democracy traditions for a predictable business climate

**Cons**
- Small domestic market size and reliance on external trade for economic growth
- Complex regulatory alignment with European Union standards despite non-member status
- Limited physical accessibility and lack of independent major transport hubs like international airports

Long story short: Europe's lowest tax rate, but good luck opening a bank account here without spending months proving you're not laundering money: that's the San Marino paradox in a nutshell.

On the flip side: a tiny administration, almost zero corruption, and total safety. The catch is that residency permits are doled out in dribs and drabs, and the banks, still burned by their own past scandals, scrutinize every wire transfer like it's a crime scene.

Beyond that: breathtaking views from Mount Titano, spot-on Italian food, and a microscopic economy permanently hitched to Italy's wagon.

## Will your income be taxed?

Long story short: NO.
**San Marino** doesn't tax personal income, and nobody comes sniffing around when you settle in. No withholding, no tax return, no centre-of-vital-interests trap waiting to snap shut.

Earn what you want: the taxman here simply doesn't know your name.

**01.1 Income tax**

| Metric | Value | Detail |
| --- | --- | --- |
| Personal income tax | NONE | no personal income tax framework |

**01.2 Tax residence test**

| Metric | Value | Detail |
| --- | --- | --- |
| 183-day rule | does not exist here |  |
| Economic interest | does not exist here |  |
| Family centre | does not exist here |  |
| Habitual abode | does not exist here |  |
| Extended-stay test | does not exist here |  |

## Will your wealth be taxed?

Long story short: NO.
**San Marino** keeps its hands off what you hold. *No capital gains tax*, no annual wealth grab, no inheritance regime.

Your portfolio compounds in peace and leaves the way it came in; nobody's standing at the door with their palm out.

**02.1 Investment income**

| Metric | Value | Detail |
| --- | --- | --- |
| Capital gains | NONE | no capital gains regime |
| Dividend tax | NONE | no dividend tax |
| Interest income | NONE | no interest income tax |

**02.2 Wealth & estate**

| Metric | Value | Detail |
| --- | --- | --- |
| Wealth tax | NONE | no annual wealth tax · no real-estate wealth tax · no net-worth assessment |
| Inheritance system | NONE | no estate tax · no heir-based duties · no succession tax framework. Wealth transfers across heir-classes are not taxed in this jurisdiction. Only standard probate / registration fees may apply. |

**02.3 Crypto**

| Metric | Value | Detail |
| --- | --- | --- |
| Crypto · tax regime | ZERO TAX | Rate: 0% · Capital gains from digital assets for individuals are exempt from income tax under Decree-Law 86/2019, Art. 14. Professional trading is treated as business income subject to progressive IGR rates (up to 35%). Source: https://www.sanmarinoinnovation.com/blockchain-decree |
| Crypto-to-crypto | NEUTRAL | a swap is not a taxable realisation event |
| FATF travel rule | NOT SIGNED | no information-sharing obligation on VASP transfers |

## Easy to run a company there?

Long story short: YES, BUT EXPOSED.
**San Marino** has *no corporate income tax* but stacks the two nastiest non-fiscal frictions: *criminal liability* for misuse of corporate assets (jail on the table for sloppy intra-company spending) and *public registries* (your name served up to anyone with a browser).

The sticker says zero; the exposure says otherwise, on every other axis.

**03.1 Rates**

| Metric | Value | Detail |
| --- | --- | --- |
| Corporate tax | NONE | no corporate income tax framework |
| VAT standard rate | NONE | no general VAT · no consumption tax framework |

**03.2 Regime & registry**

| Metric | Value | Detail |
| --- | --- | --- |
| IP Box · Patent Box | NONE | no IP regime · IP income taxed under standard corporate rules |
| Misuse of corporate assets | CRIMINAL | criminal liability · Article 198 of the Penal Code (Codice Penale) of the Republic of San Marino · San Marino follows a strict approach where 'Amministrazione infedele' (Asset Infidelity) is a criminal offense. Under Article 198 of the Penal Code (as recently updated), the crime is prosecuted 'ex officio' (automatically by the state) when committed by a company director. Because the company is a distinct legal entity (Art. 1, Law 47/2006), the state protects corporate assets independently of the shareholder's will; thus, a sole shareholder-director can be criminally liable for using company funds for personal gain even if the company is solvent. |
| Shareholders privacy | PUBLIC PAYWALL | Registro delle Imprese |
| Directors privacy | PUBLIC PAYWALL | Registro delle Imprese |

**03.3 Incorporation cost**

_In this country, the most standard company form is called Società a Responsabilità Limitata (S.r.l.) (Limited Liability Company). The costs below are for incorporating a company in its simplest form, for reference only._

| Metric | Value | Detail |
| --- | --- | --- |
| Government License Issuing Tax | USD 1,970 |  |
| Initial Company Registration Fee | USD 406 |  |
| Notary Fees, Stamp Duties, and Legal Documentation | USD 3,418 |  |
| Professional Incorporation Service Fees | USD 4,634 |  |
| Total | USD 10,427 |  |

## A good fit for a holding?

Long story short: NO.
**San Marino** has no treaty network at all, which buries the holding question, full stop.

Every dividend in or out eats the statutory withholding at full rate, and no domestic regime can patch a hole that sits on the source side. Don't park a holding here.

**04.1 Substance & exemptions**

| Metric | Value | Detail |
| --- | --- | --- |
| Territorial · individuals | WORLDWIDE | worldwide income taxation regardless of source |
| Territorial · corporates | WORLDWIDE | worldwide corporate taxation |
| Participation exemption | 95% | 5% holding · 12 months min |
| CFC rules | NONE | no controlled foreign corporation regime · foreign-source corporate income out of scope |

**04.2 Withholding tax · non-resident**

| Metric | Value | Detail |
| --- | --- | --- |
| WHT · dividends | NONE | no withholding on outbound dividends |
| WHT · interest | NONE | no withholding on outbound interest |
| WHT · royalties | NONE | no withholding on outbound royalties |
| Tax-haven WHT | NONE | no punitive rate on record |

**04.3 Treaty network**

| Metric | Value | Detail |
| --- | --- | --- |
| Treaties signed | 0 | active |
| Treaties pending | — | in negotiation |

## Easy to come and go?

Long story short: SOME.
**San Marino** taxes your worldwide income while you're resident, but at least the exit is free: *no exit tax* on the way out.

Leaving costs you paperwork, not money; your unrealised gains walk out the door with you, untouched.

**05.1 Exit & dual nationality**

| Metric | Value | Detail |
| --- | --- | --- |
| Exit tax | NONE | no triggers active · residence change tax-free · no deemed-disposal mechanism |
| Dual citizenship | FORBIDDEN | naturalisation requires renouncing existing citizenship |

**05.2 Citizenship paths**

| Metric | Value | Detail |
| --- | --- | --- |
| Residence | 20 years | available path to naturalisation |
| Marriage | 10 years | available path to naturalisation |
| Birth | — | not available |
| Descent | 1 gen | available path to naturalisation |
| Investment | — | not available |

## Is your money watched?

Long story short: YES, CLOSELY.
**San Marino** signed *every exchange framework that matters* and runs a *public corporate registry*. Whatever you do here (earn, hold, structure) is reported, searchable, or both.

Your money is watched from every angle; if discretion is part of your plan, this isn't your jurisdiction.

**Multilateral reporting frameworks — 4/9 active · 4 pending**

| Item | Status | Detail |
| --- | --- | --- |
| CRS | Signed | 2017 |
| CARF | Signed | 2024 |
| FATCA | In force | 2014 |
| MLI | In force | 2020 |
| BEPS | Signed | — |
| MAAC | In force | 2015 |
| GLOBAL FORUM | Signed | — |
| EOIR | In force | — |
| CRYPTO TRAVEL RULE | None | — |

## Is it blacklisted?

Long story short: SOMEWHAT.
**San Marino** is *flagged* by a few national tax administrations (drawn from FR/ES/PT/BR) and sits outside the FATF club.

The friction is selective: anti-abuse rules fire on specific corridors, and counterparties ask more questions than usual. Neither the FATF nor the EU has it on their lists, which keeps the damage contained: a nuisance, not a scarlet letter.

**Blacklist exposure — Listed by 2 authorities**

| Item | Status | Detail |
| --- | --- | --- |
| EMBARGO | Clear | un / us / eu sanctions |
| FATF | Clear | grey / black list |
| EU | Clear | non-cooperative list |
| FRANCE | Clear | ETNC list |
| SPAIN | Listed | tax-haven list |
| PORTUGAL | Listed | favourable regimes |
| BRAZIL | Clear | low-tax list |

## Do you feel free there?

Long story short:
Not enough data to tell how free you'd actually feel in **San Marino**.

**08.1 Press freedom**

| Metric | Value | Detail |
| --- | --- | --- |
| Press freedom · RSF index | — |  |

Central bank digital currency

NONE

no announced CBDC program · no pilot · no retail or wholesale prototype on record

## Connected to the world?

Long story short: POORLY CONNECTED.
The two rails that matter are both dead in **San Marino**. *Stripe* won't onboard you, so card payments mean a foreign structure or a local processor with its own rules. *Amazon* doesn't deliver either.

Some secondary services run (**3/11**), but for an online business this is swimming against the current.

**Accept payments — 2/6 available**

| Item | Status | Detail |
| --- | --- | --- |
| Stripe | Not available | card payments |
| PayPal | Available | wallet payments |
| Adyen | Not available | enterprise psp |
| Mollie | Not available | eu payments |
| GoCardless | Not available | direct debit |
| Paddle | Available | merchant of record |

**Bank and move money — 1/3 available**

| Item | Status | Detail |
| --- | --- | --- |
| Wise | Available | multi-currency |
| Revolut | Not available | personal banking |
| Revolut Business | Not available | business banking |

**Buy and sell on Amazon — 0/2 available**

| Item | Status | Detail |
| --- | --- | --- |
| Amazon | Not available | consumer delivery |
| Amazon Seller | Not available | marketplace selling |

  SEE ALSO## Other jurisdictions worth comparing

Picked by similarity of strategic profile to San Marino. No editorial ranking — neighbours in the same scoring space.

  PROFILE-ADJACENT Same shape, comparable overall friction.

 [   Guernsey GG  → ](https://stateless.sx/en/country/gg) [   St. Martin MF  → ](https://stateless.sx/en/country/mf) [   St. Pierre & Miquelon PM  → ](https://stateless.sx/en/country/pm)

  NOTABLY MORE FAVORABLE Same family of strategies, higher total score.

 [   Guernsey GG  → ](https://stateless.sx/en/country/gg) [   Belize BZ  → ](https://stateless.sx/en/country/bz) [   Vanuatu VU  → ](https://stateless.sx/en/country/vu)

  NOTABLY LESS FAVORABLE Same family of strategies, lower total score.

 [   Maldives MV  → ](https://stateless.sx/en/country/mv) [   Samoa WS  → ](https://stateless.sx/en/country/ws) [   Cook Islands CK  → ](https://stateless.sx/en/country/ck)