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.
This is structurally more attractive than Italy's better-known flat tax of EUR 200,000 for the merely rich. It starts at EUR 10,000 and caps at EUR 100,000. The catch is location. San Marino sits inside Italy with an open border, so Italy's Agenzia delle Entrate treats these moves with suspicion. San Marino is also not in the EU or Schengen, so the passport at the end of the process, 30 years away, is not an EU passport.
Qualifying routes
The rate is 7% on foreign income net of border costs, subject to a minimum of EUR 10,000 and a cap of EUR 100,000 per year. Because of the cap, the effective rate falls away above roughly EUR 1.43m of foreign income.
The facts
- Minimum
- €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.
- Route type
- Tax regime, not a visa
- Timeline
- 3–9 months (This is an administrative process. The figures and procedure were verified against Sammarinese professional sources rather than a directly retrievable government page.)
- Physical presence
- Applicants need 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 qualify, provided the applicant can demonstrate economic self-sufficiency for them
- Permanent residency
- Residence consolidates over 10 years.
- Citizenship
- Citizenship requires 30 years' residence. In practice, treat it as unavailable.
- Language test
- Italian is required for naturalisation.
- Dual citizenship
- Not permitted. You would have to renounce.
- Requirements
- You must never have been tax resident in San Marino before, or your residence must not yet have consolidated.Income must come from foreign sources.You must be financially self-sufficient, including for any dependants.You need a place to live in San Marino, whether rented or owned.There is a EUR 1,000 application fee. A substitute tax is paid in one instalment alongside 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 not hold up.
- 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 plan, 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. From 1 January 2026, it will apply the upgraded CRS 2.0 standard under the protocol signed with the EU on 13 October 2025.
- Neither the primary legal text nor the official agency.sm page is retrievable. 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 it has not yet taken effect.