Jurisdiction Spotlight: San Marino

San MarinoTucked away up in the Apennine Mountains of Italy, which fully surrounds the tiny nation, San Marino is the longest surviving sovereign state and republic, tracing its origins to the 3rd of September in the year 301 when it gained independence from the Roman Empire.

Since then, not much has happened in San Marino. Nations have come and nations fallen, but San Marino has remained – independent and peaceful.

The republic was briefly threatened by Napoleon but after a senior official of San Marino made friends with Napoleon, the country was left alone and at one point Napoleon allegedly offered to expand San Marino’s territory; an offer which the Sammarinese declined, stating that they are content with their mediocrity and fear that adding more territory could threaten the republic’s sovereignty in the future.

For a long time, San Marino was wealthy Italians’ own little tax haven, to a degree similar to how Cayman Islands were for the US. Vast amounts of untaxed money (not rarely originating from illicit activities) were deposited in Sammarinese banks and there was nothing Italy could do about it. Until about 10 years ago, when the climate in the international financial services were rapidly changing.

After a series of incidents, black lists, and regulatory changes, San Marino is currently a tax haven in desperate transformation. No longer able to sustain on just Italian deposits, the Sammarinese bankers and fiduciaries are taking English-classes and looking across the globe to try to compete with the likes of Andorra and Monaco.

San Marino is not a member of the EU or EEA, which can complicate running a business.

The jurisdiction has committed to CRS AEOI by 2017.

Geography and Demography

San Marino map

Full Name: Repubblica di San Marino (Republic of San Marino), sometimes Serenissima Repubblica di San Marino (Most Serene Republic of San Marino)
Official language(s): Italian
Other major languages: None
Type of government: Parliamentary democracy
Legal system: Civil law with strong Italian civil law influences
Area: 61.2 km²
Timezone: UTC+1
Population: 32,500
GDP per capita: 40,000 USD
Currency: EUR

Incorporation and Business


San Marino has no history of any significant amount of foreign-controlled companies, especially trading. Those who can place San Marino on a map usually know it’s a tax haven and if they are Italian or familiar with Italian affairs, they might have a negative associations with it.

Otherwise, it has a mostly clean reputation for doing business.


No specific regulator. Companies are answerable to the courts.


In the unlikely case that you do want to form a company in San Marino, finding someone to do it for you can be very difficult. KPMG is the only Big Four with a significant establishment in this ancient republic. And KPMG charges Big Four prices.

Smaller law firms or accountants may be a cheaper option but you might be surprised by how limited their English is.

A handful of incorporation mills offer San Marino, often at outrageous cost and extremely misleading information as a result of rampant copy-paste and complete disregard for accuracy.

Incorporation usually takes two to three months.

All incorporation documents are in Italian.

Companies owned and managed entirely by non-residents must submit background checks proving no criminal wrongdoings.

SRL (Società a Responsabilità Limitata)

This is the most popular company type in San Marino. It is comparable to GmbH under German law, SRL under Spanish law, and – to a lesser extent – the LLC.

  • Minimum 25,500 EUR share capital of which 12,500 EUR must be paid up.
  • Minimum one director. Cannot be corporate.
  • Minimum one shareholder. Can be corporate.
  • Can be single-member.
  • No residency requirements.
  • Audits are optional unless share capital exceeds 77,000 EUR or revenue exceeds 2 million EUR.
  • Ownership divided by quotas (must be registered).
  • Must have registered office in San Marino.

SpA (Società per Azioni)

A lot less popular than the SRL. Akin to AG under German law, SA under Spanish law, and share companies/corporations under English and American law.

  • Minimum 77,000 EUR share capital, of which 50% must be paid up (usually 100% is paid up).
  • Minimum one director. Cannot be corporate.
  • Minimum one shareholder. Can be corporate.
  • Cannot be single-member.
  • No residency requirements.
  • Audits are mandatory.
  • Ownership divided by shares (must be registered, i.e. no bearer shares).
  • Must have registered office in San Marino.


Companies are taxed at 17% on their worldwide income, although there are numerous deductions and incentives available to reduce this tax rate significantly (to well under 10%).

Additionally, there is a 1,000 EUR per year minimum trading license fee for trading businesses.

Record Keeping

Required and returns must be filed.

Public Records

Members and company details appear on public records.


There are a number of laws which dictate how trusts function in San Marino, with the most important piece being the International Trust Law of 2012.

The law is almost entirely based on the English model and Hague convention, and is an attempt by San Marino to draw in new clients with a new product. It has so far seen moderate success.

It is not a very strong trust law. Forced heirship is possible under certain circumstances.


Banking is the strongest pillar of San Marino’s international financial service sector. It has suffered tremendously from the withdrawal of (sketchy) Italian wealth and the banks are scurrying to rebrand themselves as international and English-speaking-friendly.

Banking is of generally pretty high quality, if you are OK with Italian and/or broken English.

It can be hard to open accounts other than EUR sometimes and card products are often unimpressive.

From speaking to Sammarinese banks, though, they all seem to have plans to modernize and improve their services in the coming years. This is similar to what Andorran banks started doing a few years ago and of which we are starting to see the result today.

Open a Bank Account in San Marino

It’s difficult but can often be done remotely, sometimes directly but usually via an intermediary of some kind.

The compliance and paperwork is not significantly different from elsewhere, falling within European standards.

It used to be that banks insisted on Italian translations of all documents but requirement is often waived nowadays.

Banking Secrecy

The Sammarinese banking secrecy was once on par with Switzerland, Liechtenstein, and even Lebanon. Following a couple of embarrassments and criticism by Italy, EU, and OECD, it has since been eroded to the point of being strict but in line with international standards, including the CRS AEOI.

Banks in San Marino

Banks in San Marino are under supervision of the Banco Centrale della San Marino (BCSM). It is a perhaps surprisingly well-functioning and modern institution.

There are seven banks in San Marino:

Living in San Marino

If you ever wanted to live up in the mountains surrounded by stunning Italian scenery without the tax and bureaucratic nightmare of Italy, San Marino might be just what you want — although you might want to consider the south of Switzerland or even Campione d’Italia (more on that another day).

Costs of living are generally quite low.


It used to be a lot easier to set up a company in San Marino and move settle down there. However, after being strong-armed into signing a tax deal with the EU, this is no longer as popular as it was before.

It’s still possible and can turn out to render significant tax savings, but it’s debatable if it’s any better than other European tax havens or low-tax jurisdictions.


A huge hassle that’s not worth it.

Requires 30 years of residency and renunciation of other citizenships prior to application (statelessness).


San Marino is not a zero-tax jurisdiction.

There are in fact a lot of different taxes in San Marino, although many of them are low and rendering an overall tax pressure that is comparable to the rest of western Europe.

Regular income tax can reach brackets of 50% (income over 230,000 EUR), whereas dividends, royalties, and capital gains incomes can be enjoyed at a much lower tax rate in many cases.

An income of 100,000 EUR would render an effective income tax in the vicinity of 30%.

Final words

A tax haven fallen from (dis-)grace. Superficially attractive for certain for business, San Marino’s most attractive aspect is its banking system and a relatively attractive tax climate for natural persons.

Not much else to say about this tiny, ancient, proud, and most serene republic.

See also

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