San Marino · Tax regime
Residenza Atipica (atypical residence under the favourable tax regime)
Open. Available to individuals who have never been tax resident in San Marino, or who have not yet consolidated tax residence there, and who produce foreign-source income.
Structurally more attractive than Italy's better-known EUR 200,000 flat tax for the merely-rich: it starts at EUR 10,000 and caps at EUR 100,000. The catch is that San Marino sits inside Italy with an open border, so the Italian Agenzia delle Entrate treats these moves with suspicion — and San Marino is not in the EU or Schengen, so the passport at the end (30 years away) is not an EU one.
Qualifying routes
7% on foreign income 'netto frontiera', subject to a minimum of EUR 10,000 and a CAP of EUR 100,000 per year. The cap means the effective rate falls away above roughly EUR 1.43m of foreign income.
The facts
- Qualifying figure
- €10k
- Total landed cost
- EUR 10,000 minimum to EUR 100,000 maximum in annual substitute tax, plus a EUR 1,000 application fee and the cost of renting or owning a San Marino home
- Timeline
- 3–9 months — Administrative process; figures and procedure verified against Sammarinese professional sources rather than a directly-retrievable government page
- Physical presence
- Requires availability of a dwelling in San Marino, owned or rented, and genuine residence — Italy's tax authorities scrutinise San Marino moves closely given the open border
- Family
- spouse and dependent family members, subject to demonstrating economic self-sufficiency for them
- Permanent residency
- Consolidation of residence over 10 years
- Citizenship
- 30 years' residence — treat citizenship as unavailable
- Language test
- Italian required for naturalisation
- Dual citizenship
- Not permitted — you would have to renounce
- Requirements
- never previously tax resident in San Marino, or residence not yet consolidatedforeign-source incomeeconomic self-sufficiency including for dependantsavailability of a dwelling in San Marino, rented or ownedEUR 1,000 application fee; substitute tax paid in a single instalment with the annual IGR balance
- Proximity to Italy is the central risk. With an open border and no formal Schengen membership, Italian residence tests are the real threat — a San Marino address that does not reflect where you actually live will fail.
- San Marino is NOT in the EU and NOT formally in Schengen. Residence here grants no EU rights.
- Citizenship requires 30 years and San Marino does not permit dual citizenship — this is a tax residence, not a passport plan.
- The 7% regime applies to foreign-source income only; San Marino-source income is taxed under the ordinary IGR.
- San Marino is a CRS participant and exchanges information — and from 1 January 2026 applies the upgraded CRS 2.0 standard under the protocol signed with the EU on 13 October 2025.
- We could not retrieve the primary legal text or the official agency.sm page (the server refused connections throughout this research). The figures here are corroborated across several independent Sammarinese accounting and law firms plus a government-linked summary, but should be confirmed with the Ufficio Tributario before acting.
- The EU–San Marino association agreement, whose text was agreed in December 2023, remains in ratification as of 2026 — it would change the access picture materially but has not yet taken effect.