San Marino Atypical residence

Residence for people who live in San Marino on income produced abroad, with a 7% substitute tax on net foreign-source income of at least EUR 10,000 (≈ $11,200) and at most EUR 100,000 (≈ $112,000) a year. ^{1 2 3 4 5 6 7}

What you must show and pay

• A fee of EUR 10,000 a year (≈ $11,200) · Minimum annual substitute tax (7% of net foreign-source income, maximum EUR 100,000 (≈ $112,000)), due every tax year even when the foreign-source income is not taxable in San Marino under a tax treaty, from tax year 2026. ^{7 6}
• A fee of EUR 1,000 (≈ $1,120) · State application fee that covers stamp duties and office charges (Art. 16-ter). ¹

Requirements

• Applicant has never been tax resident in San Marino or had not consolidated registered residence when Law 223/2020 took effect. ^{1 4}
• Applicant produces income abroad. ¹
• Applicant has no criminal conviction or pending case that bars a permit under Art. 17. ¹
• Pay a 7% substitute tax on net foreign-source income (after tax paid abroad), at least EUR 10,000 (≈ $11,200) and at most EUR 100,000 (≈ $112,000) a year, even if a tax treaty leaves the income untaxed. ^{7 6}
• Valid travel document, certified as authentic by the official receiving the application. ¹
• Preliminary contract to buy or rent a home, subject to the grant of residence. ¹
• Certificate of residence, criminal record and pending charges, or equivalents, plus a sworn declaration on nationalities, residences in the last 5 years and tax compliance. ¹
• Proof that the applicant and relatives have enough resources to support themselves. ¹
• Health insurance valid in San Marino. ^{4 2}
• Apply to the Department of Foreign Affairs with the receipt for the EUR 1,000 (≈ $1,120) application fee; the Congress of State decides within 60 days and the decision cannot be appealed. ¹
• A provisional stay permit of up to 6 months can be obtained while the residence application is processed. ¹
• No more than 100 residences are granted each year, not counting secondary applicants; the figure can be changed yearly by decree. ¹
• The application fee is EUR 1,000, (≈ $1,120) which covers stamp duties and office rights. ¹
• The regime also covers family members whose residence is extended, except children who are fiscally dependent until they stop being dependants. ⁷
• Residence consolidates after 10 years on the register; the tax regime itself ends after 15 years from the first tax year. ¹
• Holders may not take public-sector jobs or state benefits until residence consolidates. ^{1 4}

Stay

• Registered residence; it consolidates after 10 years and the facilitated tax regime lasts at most 15 years.
• Atypical residence up to 120 months: Consolidates after 10 years; tax regime ends after 15 years

Work

Income from employment, self-employment, business and capital produced abroad falls under the regime; public-sector jobs are barred until residence consolidates.

Family

Spouse and children up to 25 can be added as secondary applicants under Art. 16(3-bis) of Law 118/2010; the substitute tax also applies to extended family members, except fiscally dependent children.

Checked 2026-10-11

Official sources

1. Law 118/2010 on entry and stay of foreigners, consolidated text updated to 9 April 2024 · Department of Foreign Affairs, Republic of San Marino · checked 2026-10-11
2. Law 223 of 23 December 2020, Articles 69 and 70 (atypical residence regimes) · Department of Foreign Affairs, Republic of San Marino · checked 2026-10-11
3. Collection of main circulars on the general income tax (IGR) · Tax Office, Finance and Budget Department, Republic of San Marino · checked 2026-10-11
4. Stay permits, residence and citizenship · Department of Foreign Affairs, Republic of San Marino · checked 2026-10-11
5. Permessi di soggiorno, residenze e cittadinanza (Italian index with forms and checklists) · Department of Foreign Affairs, Republic of San Marino · checked 2026-10-11
6. Law 118/2010 on entry and stay of foreigners, coordinated text updated to 3 June 2025 · Consiglio Grande e Generale of San Marino · checked 2026-10-11
7. Delegated Decree 150 of 5 October 2026 (ratification of Delegated Decree 115/2026): atypical-residence tax and residence for economic reasons · Consiglio Grande e Generale of San Marino · checked 2026-10-11
8. Cittadinanza per naturalizzazione (FAQ on residence years) · Government of San Marino (GOV.SM) · checked 2026-10-11