San Marino

The Residenza Atipica regime applies a 7% substitute tax on foreign-source income, calculated net of certain border-related deductions. The tax has a floor of EUR 10,000 and a ceiling of EUR 100,000 per year, plus a EUR 1,000 application fee. Because the tax caps at EUR 100,000, the effective rate starts to shrink once foreign income passes roughly EUR 1.43m. The regime is open to people who have never been tax resident in San Marino, or who have not yet established residence there, and who earn foreign-source income. Income sourced within San Marino is taxed differently, under the ordinary progressive IGR.

It is structurally more attractive for the merely-rich than Italy's better-known regime. San Marino starts at EUR 10,000 and caps at EUR 100,000, while Italy's flat tax on foreign income sits at EUR 200,000 a year. The catch is location. San Marino sits inside Italy with an open border, so Italy's Agenzia delle Entrate watches these moves closely, and San Marino is neither in the EU nor formally part of Schengen. In practice, you trade a lower absolute tax bill for a weaker legal position and a passport that, decades from now, still would not be an EU one.

Yes, and that is the central risk. The regime requires a genuine dwelling in San Marino, owned or rented, and real, lived-in residence. A San Marino address that does not match where you actually live will not hold up. Because the border with Italy is open and San Marino is not formally part of Schengen, Italian residence tests are the real threat. The Agenzia delle Entrate treats enclave-based moves with real suspicion. Anyone considering this route needs to be ready to actually relocate into a 61 km2 enclave, not just register an address there.

The Residenza per Motivi Economici route has the lowest entry point. It requires a financial guarantee of EUR 75,000 in years one and two, rising to EUR 150,000 from year three, in exchange for owning at least 51% of a San Marino company. This is a genuine operating commitment, not a paper structure. You must actively run the business and hire employees from the official San Marino employment lists. The company itself pays 17% corporate IGR, even if you use the 7% personal regime on foreign income. It suits operators, not passive investors.

The Residenza Elettiva route requires either purchasing a dwelling for at least EUR 500,000, or a EUR 600,000 non-interest-bearing deposit in state securities locked for 10 years, on which a EUR 10,000 one-off tax applies. A property to be renovated also qualifies, as long as the purchase price plus the cost of works reach that figure, with renovation counting up to EUR 150,000. Add a EUR 1,000 first-request fee and EUR 20,000 one-off per accompanying family member. Only 50 elective residences are granted per year. The deposit route is quietly punitive. The money sits locked and earning nothing for a decade, so its real cost is the yield you give up, roughly EUR 300,000 of compound return at 4%. That makes the property route usually the better economic choice, since you end up keeping an asset.

Treat citizenship as effectively off the table. It requires 30 years of residence, and San Marino does not allow dual citizenship. That means renouncing your other nationalities and passing an Italian-language test. Residence itself only becomes permanent after 10 years. This is a tax-residence plan, not a passport plan. Elective residents are also barred from public-sector jobs during that 10-year consolidation period. Anyone who sells San Marino as a citizenship route on any reasonable timeline is misrepresenting it.

No. San Marino belongs to neither the EU nor, formally, Schengen. Residence there grants none of the EU's rights to free movement, work or establishment. An EU-San Marino association agreement had its text agreed in December 2023 and remains in ratification as of 2026. If it takes effect, it would change the access picture materially. It has not yet done so. For now, San Marino is a tax base surrounded by Italy, not a gateway to Europe.

Yes. San Marino participates in CRS and exchanges information with other tax authorities. From 1 January 2026, it applies the upgraded CRS 2.0 standard under the protocol signed with the EU on 13 October 2025. There is no banking secrecy benefit here. The 7% regime lowers your San Marino tax bill on foreign income. It does nothing to keep your accounts private from your home tax authority.