Living in San Marino: residency by registration, stay or vital interests, tax of 10,000 euros for non-domiciled residence

This page reports on information published by the Parliament of San Marino (Consiglio Grande e Generale), the Government, the State Secretariat for Finance and Public Finances of San Marino, and the BOFiP (Official Bulletin of Public Finances). Law No. 166 of December 16, 2013, on General Income Tax (IGR), classifies as residents any person who meets at least one of three conditions: residence registered in the population register, residence, or center of vital interests in San Marino. Residents are taxed on their income wherever it is generated. Law No. 132 of September 15, 2023, further provides for a "non-domiciled tax residence," with an annual tax of €10,000.

Between France and San Marino, the BOFiP (Official Bulletin of Public Finances) indicates an information exchange agreement dated September 22, 2009, which entered into force on September 2, 2010, and does not list any tax treaties. The progressive income tax scale is not detailed here.

Tax residency: three alternative criteria

Article 10, paragraph 2, of Law No. 166 of December 16, 2013, in its promulgated text published by Parliament, considers as residents natural persons for whom, in the reference tax period, at least one of the following conditions is met:

• they have their residence registered in the state population register (anagraphic residence) for most of the tax period;
• they remain in the territory of the State for most of the taxation period;
• They have the center of their vital interests in the territory of the State.

Article 2 defines the center of vital interests as the concentration within the territory of the State of the prevalence of a person's economic, financial, social, and family interests. Explanatory Circular No. 7 from the State Secretariat for Finance and Accounting, dated September 2, 2014, reiterates these three conditions. Law No. 141 of November 12, 2025, does not redefine tax residence.

Scope of taxation and property taxes

According to Article 1 of the 2013 law and the 2014 circular, residents are taxed on all their income, wherever it is generated. Non-residents are taxed only on income deemed to be generated within the state: Article 5 first mentions income from land and buildings located within the state's borders.

The government's online services portal (gov.sm) lists, alongside income tax returns (IGR), returns for the Extraordinary Real Estate Tax (ISI) and the Extraordinary Property Tax (IPS). Their bases and rates are not detailed here.

Progressive scale and reform applicable since 2026

Article 17 of the 2013 law refers, for the progressive taxation of individuals, to Table 1 of Appendix C. This page does not reproduce this table. Appendix C, Article C1, paragraph 2, in the version amended by Law No. 141 of November 12, 2025, provides that the tax brackets are automatically adjusted every two years based on changes in the cost of living index.

Law No. 141/2025 applies from the 2026 tax year (Article 54, paragraph 1); the previous rules continue to apply to periods before 2026 (paragraph 2). It includes, in particular:

• a tax deduction for expenses for goods and services carried out in the Sammarin territory, within the framework of the SMaC scheme (article 16, paragraphs 8 bis and 8 ter), capped at the tax due;
• a proportional rate of 18 % instead of 17 % for the tax periods 2026 to 2030, on the income referred to in Article 13, paragraph 1, letters a) and l), and in Article 43 of the Law of 2013 (Article 54, paragraph 6); at the session of 5 November 2025, the Secretary of State for Finance presented this increase as relating to economic activities.

Table No. 1 of Annex E of Law No. 141/2025 sets the maximum deduction according to taxable income.

Article 4 of Law No. 141/2025 replaces Article 13 of the 2013 Law from the 2026 tax year. Paragraph 1 lists the income taxed separately; paragraph 2 sets the following rates: 17 % for self-employment and business income of economic operators (letter a) and for end-of-term allowances for company directors (letter l), increased to 18 % from 2026 to 2030 (Article 54, paragraph 6); 10 % for capital gains referred to in Article 41 (letter b); At the taxpayer's option, 3 % of the "netto frontiera" for dividends from foreign sources (letter g), 10 % of the "netto frontiera" for interest, premiums, and other income from foreign bonds or debt securities other than shares (letter h) and for income from insurance contracts referred to in Article 19, paragraph 1, letter f bis) (letter m), and 13 % of the "netto frontiera" for interest on current accounts opened with foreign financial institutions (letter i). This page does not provide details on the concept of "netto frontiera," Article 41, or the other letters in paragraph 1.

Non-domiciled tax residence (Law No. 132/2023)

Articles 12 and 13 of Law No. 132 of September 15, 2023, published on gov.sm, establish a temporary residence permit of 30 to 150 days per calendar year for individuals staying in a superior hotel establishment. The text specifies, in particular:

• an annual tax of 10,000 euros per person, payable upon admission to the hotel or within 30 days of authorization, non-refundable, not due for minors under 18 years of age;
• This tax replaces certain residence fees and Sammarin taxes on income produced in the territory, except for two categories of income (table below);
• the applicant must not have been a tax resident of San Marino or any high-risk country during the previous seven years, nor be subject to prosecution or conviction for certain serious offences;
• the title is issued per calendar year and expires on December 31; the holder is not entitled to free healthcare or to Sammarin social security;
• Existing international agreements on double taxation and the exchange of information remain in force.

The minutes of the Parliament meeting of June 12, 2025, report the rejection, by 34 votes to 11 with one abstention, of a motion calling for the repeal of the regulations and circulars concerning these residences. They also report that a councillor stated that no permits had been issued to date, and that a reform of these residences had been announced, without providing further details.

Coordination with France: information exchange agreement

The BOFiP list of agreements relating to the exchange of tax information (BOI-ANNX-000307, version of June 21, 2019) indicates for San Marino: agreement of September 22, 2009, which entered into force on September 2, 2010. The same BOFiP mentions Decree No. 2010-1210 of October 13, 2010, publishing the agreement. The list of tax treaties (BOI-ANNX-000306), which covers agreements in force on January 1, 2026, does not include any entry for San Marino. This list, however, mentions information exchange agreements with other states (for example, Andorra, agreement of September 22, 2009): the 2009 agreement with San Marino is not included. This page presents both lists without distinguishing between them.

Without a tax treaty, no treaty exists to distinguish between dual residences. France applies its domestic law: according to the French Tax Administration's Official Bulletin (BOFiP) (BOI-IR-CHAMP-10, version of July 28, 2016), Article 4 B of the French General Tax Code (CGI) defines tax residence as the home or principal place of residence in France, the exercise of a professional activity in France, or the center of economic interests in France. For income from foreign securities, the BOFiP (BOI-RPPM-RCM-20-10-20-60, version of December 29, 2016) indicates that income from a country without a tax treaty is not eligible for any credit against French tax: it is subject to French tax on its net amount after foreign tax. It must be declared on form 2047, attached to tax return 2042.

Leaving France falls under exit tax and tax residence, which are discussed in our pages on these topics.

What this page does not cover

It does not detail the progressive income tax brackets and rates, the concept of "netto frontiera" (border tax), property acquisition by a foreigner, inheritance and gift tax, social security contributions, or standard residence permits. These matters fall under San Marino law and should be verified with the State Secretariat for Finance and Accounting (Segreteria di Stato per le Finanze e il Bilancio) or the Tax Office (Ufficio Tributario). Balmont Conseil is neither a law firm nor a local tax advisor: local tax matters should be verified with a professional based in San Marino. French matters, particularly the departure declaration and the accounts to be declared, are addressed in our pages on tax residency and exit tax.

What changes depending on your situation

• The length of stay in the tax year, registration in the population register and the location of the center of your vital interests.
• The nature of income: salary, self-employment, dividends, interest, rent, capital gains.
• The regime in question: ordinary residence or non-domiciled tax residence permit, with its annual tax.
• Your tax residence in France and San Marino, year by year.

The rule depends on your situation. No results are guaranteed.