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INTERNATIONAL TAXATION

The Ministry of Finance and Budget is at the forefront of efforts to allow the Republic of San Marino to comply with the international tax standards proposed and updated by the Organisation for Economic Co-operation and Development (OECD).
Indeed, San Marino resources are coordinated by the Department of Finance and Budget, through a constant dialogue with OECD counterparts, in order to facilitate the maintenance of the country’s reputation in a process focused on
transparency and international cooperation.


SAN MARINO ALIGNMENT PROCESS


Since 2008, San Marino has been engaged in a process of transparency and international cooperation.

Over the years, a number of actions and measures have been taken in the field of exchange of information in tax matters. Indeed, since April 2009, the Republic of San Marino has signed a significant number of Tax Information Exchange Agreements (TIEAs) and Double Taxation Agreements (DTAs) with numerous countries and jurisdictions in accordance with the new standards of the Organisation for Economic Co-operation and Development (OECD).

Thanks to these important steps, on 23 September 2009 San Marino was included in the OECD White List, positioning itself among the virtuous countries that have met the highest standards of transparency and international cooperation, demonstrating its commitment to adopting best practices.

The Ministry of Finance and Budget is fully aware of the fundamental steps undertaken that have improved San Marino's reputation on the international scene. It intends to continue to make efforts at the operational level, so that San Marino economic system can remain aligned with the commitments undertaken with the OECD.

List of DTAs


 

This section, focused on the international bilateral treaties signed by the Republic of San Marino with other countries to avoid double taxation, contains:
 

 

CONVENTION BETWEEN THE REPUBLIC OF SAN MARINO AND THE ITALIAN REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION ON INCOME AND THE PREVENTION OF TAX FRAUD signed on 21 March 2002 and entered into force on 3 October 2013;
AMENDMENT PROTOCOL signed on 13 June 2012 and entered into force on 3 October 2013;.
EXPLANATORY CIRCULARS ON THE APPLICATION OF THE ARTICLES OF THE DTA with the Italian Republic, issued by the Secretariat of State for Finance and Budget in 2014.

INFORMATION EXCHANGE


Law no. 174 of 27 November 2015 regulate international tax cooperation implemented by the Republic of San Marino to enforce international, bilateral or multilateral agreements concluded with foreign countries or jurisdictions.

The agreements include:

  1. Multilateral Convention on Mutual Administrative Assistance in Tax Matters signed in Jakarta on 21 November 2013 (MAC); 
  2. bilateral agreements to ensure exchange of information in tax matters on request according to OECD standards (TIEAs);
  3. bilateral agreements to eliminate double taxation according to OECD standards and including the provisions on exchange of information on request (DTAs);
  4. the agreement with the Government of the United States of America (IGA SM) and relevant technical arrangements to implement FATCA tax compliance standard;
  5. any other international agreement providing for international tax cooperation, referred to by the ratifying measure in San Marino legal system for the enforcement of Law no. 174/2015.

 

For the latest information, please visit the following website: https://www.gov.sm/pub1/GovSM/clo/

CENTRAL LIAISON OFFICE (CLO)

OECD STANDARDS: RELATIONS WITH THE OECD AND INTERNATIONAL TAXATION


The Ministry of Finance and Budget of San Marino is at the forefront of ensuring the Republic's alignment with the international tax standards proposed and updated by the OECD. This commitment is reflected in ongoing dialogue with OECD representatives, aimed at maintaining the country's excellent reputation, founded on transparency and international cooperation. A key step in this process was San Marino's participation in the BEPS (Base Erosion and Profit Shifting) project, communicated to the OECD on June 21, 2016. With this participation, San Marino joined the Inclusive Framework, an initiative with nearly 150 jurisdictions collaborating to combat tax avoidance practices by multinationals that aim to reduce tax bases and shift profits to low- or no-tax jurisdictions. The implementation of BEPS standards has strengthened San Marino's position as a transparent and internationally aligned jurisdiction, making it attractive to serious investors and distinguishing it from uncooperative jurisdictions. Finally, in 2021, San Marino further reaffirmed its commitment by joining the Declaration on a Two-Pillar Solution to Address the Tax Challenges Resulting from the Digitalization of the Economy. This political agreement aims to clearly define the scope of Pillars I and II for the taxation of the digital economy, consolidating San Marino's role in the international tax community.

BEPS PROJECT
TWO-PILLAR SOLUTION