San Marino
San Marino S.r.
Foreign Ownership Eligibility
San Marino welcomes 100% foreign-owned companies
A physical visit is required at some point during the formation process.
- 100% foreign ownership permitted — no mandatory local shareholder or director required for S.r.l. or S.p.A.
- S.r.l. minimum share capital: €2,500; S.p.A. minimum: €25,500 — capital must be deposited in a San Marino bank before registration
- Pre-approval from the Economic Planning Department (Dipartimento Finanze e Bilancio) is mandatory before filing — requires a business plan submitted in Italian
- Company statutes (atto costitutivo) must be drafted in Italian and notarised before a San Marino notary
- Foreign shareholders must provide notarised and apostilled identity documents (passport) and proof of address
- Annual statutory audit is required for all S.r.l. and S.p.A. companies
- Tax registration with the Ufficio Tributario required after incorporation; social security registration with ISS required if hiring employees
Ownership
100% Foreign OK
Formation
Visit Required
Note
Physical presence is required to sign company statutes before a San Marino notary and to open a corporate bank account in San Marino. Remote incorporation is not possible — the notarisation step requires in-person attendance or a locally authorised representative with notarised power of attorney.
Tax at a glance
San Marino Tax Overview
17%
Standard corporate income tax (IGR)
Applies to most companies; versus Italy's combined IRES+IRAP of approximately 23.9%
8.5%
CIT for new businesses with employees
First 5 years; conditions: hire ≥1 employee within 6 months and ≥2 employees within 24 months — verified via startup.sm
0%
CIT for innovative startups — years 1–3
Official startup.sm programme; rises to 4% in years 4–7 and 8% in years 8–12
4%
CIT for innovative startups — years 4–7
Second phase of the startup.sm incentive ladder after the initial 3-year zero-tax period
8%
CIT for innovative startups — years 8–12
Third and final phase of the startup.sm incentive ladder
0%
Consumption tax on services
Imposta monofase applies only to imported goods (17%); no consumption tax applies to services in San Marino
17%
Imposta monofase on imported goods
Single-stage import tax levied once at the point of importation; replaces VAT; does not apply to services
5%
Withholding tax on dividends to individuals
Standard rate; qualifying non-resident companies holding ≥12 months benefit from a 95% exemption — effective WHT approximately 1%
13%
Withholding tax on interest
Applies to interest payments; relevant for loan and debt structures
20%
Withholding tax on royalties to non-residents
Material cost for IP-heavy or licensing-focused business models
9%–35%
Personal income tax (IRPEF)
Progressive: 9% up to €10,000; 13% on €10,001–€25,000; 35% above €25,000 — lower top rate than Italy's 43%
Pros & cons
Advantages & Considerations
Key Advantages
No VAT on services. San Marino uses the imposta monofase — a single-stage import tax of 17% levied only on imported goods, not on services. Service businesses operating out of San Marino face zero consumption tax on their services. No EU-neighbouring jurisdiction operates without a VAT-equivalent tax on services.
17% corporate income tax (IGR) — approximately 6.9 percentage points lower than Italy's combined IRES+IRAP rate of approximately 23.9%. For Italian-adjacent businesses choosing between Italy and San Marino, this is a material tax saving on every euro of profit.
0% CIT for years 1–3 for innovative startups under the official startup.sm programme, rising to 4% for years 4–7 and 8% for years 8–12. One of the most graduated startup tax incentive regimes in Europe, fully verified via startup.sm (official San Marino government startup portal).
8.5% CIT for the first 5 years for new businesses that hire at least 1 employee within 6 months and a 2nd employee within 24 months of formation — sourced from startup.sm.
95% dividend exemption for non-resident companies that have held their participation continuously for at least 12 months. Effective withholding tax on qualifying dividends to corporate shareholders is approximately 1% rather than the standard 5%.
Up to 90% reduction in taxable income for capital goods and real estate investments — relevant for capital-intensive businesses considering San Marino as a base.
Customs union with Italy and the EU means goods move freely between San Marino and all EU member states without customs duties, while San Marino retains its own tax regime outside the EU VAT area.
Euro currency with no foreign exchange risk. San Marino uses the Euro under a monetary agreement with the EU Council — no conversion costs for Italy-facing businesses.
100% foreign ownership permitted. No mandatory local shareholder or director requirement for S.r.l. or S.p.A. entities.
Double tax treaties with Italy, France, Romania, Sweden, Malta, Qatar, UAE, and others. OECD Multilateral Convention (MLI) signed and aligned with BEPS minimum standards. FATCA agreement with the USA signed.
Personal income tax (IRPEF) top rate is 35% — lower than Italy's 43% top rate. Relevant for founders who establish residency in San Marino.
5% withholding tax on dividends paid to individuals — lower than comparable rates in several European jurisdictions.
Considerations
San Marino's domestic market is approximately 34,000 people — one of the smallest in Europe. The value proposition is the tax structure and proximity to Italy, not domestic market access or customer base.
San Marino's banking sector experienced a severe crisis from 2008 to 2014, resulting in the collapse of multiple institutions and a prolonged restructuring period. Some international correspondent banks apply enhanced due diligence to San Marino entities as a result. Account opening requires notarised company documents and a beneficial ownership declaration.
Foreign investors must obtain pre-approval from the Economic Planning Department (Dipartimento Finanze e Bilancio) before incorporating. This review requires a business plan submitted in Italian and adds 1–3 weeks to the formation timeline. No comparable pre-approval step exists when incorporating in most EU member states.
San Marino is not an EU member. While it has a customs union with Italy and the EU for goods, it is outside the EU single market, the EU VAT area, and EU financial services passporting frameworks — relevant for any business regulated at EU level.
Royalties paid to non-residents are subject to 20% withholding tax; interest payments are subject to 13% withholding tax. These rates are material for IP-heavy or licensing-focused structures and should be modelled before choosing San Marino.
All company statutes (atto costitutivo) must be drafted in Italian and notarised before a San Marino notary. This adds a mandatory professional cost and requires Italian-language legal support regardless of the founder's language.
Structural Comparison
S.r.l. (Società a Responsabilità Limitata)
S.p.A. (Società per Azioni)
Branch of a Foreign Company
Incorporation Process
The process is strictly digital. Each stage builds on the previous one.
Free consultation with XBandGlobal specialists to confirm the right entity structure (S.r.l. or S.p.A.), verify startup incentive eligibility under the startup.sm programme, and outline realistic costs and timelines including the mandatory DEP pre-approval step.
Prepare a business plan and supporting documentation in Italian for submission to the Economic Planning Department (Dipartimento Finanze e Bilancio). XBandGlobal's San Marino partners assist with Italian-language business plan preparation and DEP submission requirements.
Submit the pre-approval application to the Economic Planning Department. The DEP reviews the proposed business activity, corporate structure, and economic substance. Allow 1–3 weeks for this stage; complex structures or unusual business activities may take longer.
Draft company statutes (atto costitutivo) in Italian, defining the company name, registered office in San Marino, share capital, shareholders, and directors. XBandGlobal coordinates with a local law firm for statute preparation.
Sign and notarise the company statutes and all founding documents before a San Marino notary. Foreign shareholders must provide notarised and apostilled identity documents. In-person attendance or a locally authorised representative with notarised power of attorney is required at this stage.
What you'll pay
Cost Architecture
Government Fees
Annual Ongoing
Professional Services
The minimum share capital figures (€2,500 for S.r.l., €25,500 for S.p.A.) are capital contributions to the company — not fees — and are released to the company's working capital after registration. The genuine upfront professional cost is notary fees, legal preparation, and DEP pre-approval documentation. Estimated total professional services for S.r.l. formation: approximately €2,000–5,000 before ongoing annual compliance.
Still unsure about costs?
These are estimates — your actual cost depends on your structure
Every San Marino setup is different. A 15-minute call with one of our specialists will give you a personalised cost breakdown — completely free.
Fintech & Banking
Can non-residents open accounts without visiting? NO.
Banking options for non-resident founders in San Marino. Remote account opening availability varies by institution.
| Institution | Type | Ease for Non-Residents | Notes |
|---|---|---|---|
| Banca di San Marino (BSM) | San Marino domestic bank | Low (Visit Required) | One of the main domestic banks following the 2008–2014 sector restructuring. Account opening requires notarised company documents and a beneficial ownership declaration. Enhanced KYC applies to foreign-owned entities; account approval timelines vary. |
| Cassa di Risparmio della Repubblica di San Marino | San Marino savings bank | Low (Visit Required) | Historically significant savings institution serving business clients. In-person presence or a locally authorised representative with notarised power of attorney is required. Thorough AML and beneficial ownership documentation required at opening. |
| Italian banks (cross-border accounts) | Italian licensed commercial banks | Low (Visit Required) | Many San Marino businesses maintain accounts with nearby Italian banks (e.g., Unicredit, Intesa Sanpaolo) for operational convenience, given San Marino's customs union with Italy. Italian banks apply standard Italian KYC requirements; foreign-owned San Marino entities may face additional AML scrutiny from Italian compliance teams. |
Frequently Asked
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