San Marino Atypical Tax Residence

The San Marino Tax Residence Scheme (Officially Atypical residence subject to a facilitated tax regime), offers a residence permit with preferential tax treatment for foreign citizens who generate income abroad. With no minimum investment requirement beyond a minimum annual tax of €10,000.

The permit requires minimum physical presence of 183 days per year and offers a path to permanent residency after 10 years of maintaining the atypical residence status, during which the holder must continue generating income from abroad.

Applicants must:

• Be foreign citizens who have never resided in San Marino for tax purposes

• Not have obtained final registered residence before 2020

• Generate income from abroad

• Maintain valid health insurance coverage

Foreign-source income is subject to a simplified flat tax regime:

• 7% tax rate on worldwide income

• Minimum annual tax payment: €10,000

• Maximum annual tax cap: €100,000

• Applicable only to income generated outside San Marino

• Freedom of movement (but not settlement) within Schengen
• Lower taxes
• Safety and security
• Short processing time
• Enhanced business access to large economies

After maintaining uninterrupted residency in San Marino for 30 years, applicants become eligible to apply for citizenship. Requirements include:

• Demonstrating Italian language proficiency
• Renouncing existing citizenship(s), as San Marino does not permit dual nationality

Browse 195 countries’ paths to citizenship in the hyper-detailed IMI Citizenship Catalog.

Applications for this program may be directed to San Marino Ministry of Foreign Affairs.

Legislation upon which this program is based Law no. 223/2020.