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Economy and Banking Sector of San Marino

Withholding Tax

Withholding taxes are imposed at source of income and are often applied to dividends, interest, royalties, rent and similar payments. The rates of withholding tax are often reduced by double taxation agreements.

Withholding Tax Rates in San Marino: 0.0 - 11.0%

Withholding tax rates applied on payments of interest and dividends in San Marino are shown in Table 1.

Dividends Interest
Natural person, resident 0.0 %11.0 %
Natural person, non-resident 0.0 %11.0 %
Table 1. Withholding tax rates in San Marino.

Double Taxation Agreements

Double Taxation Agreement (DTA) is an agreement between two or more countries for the avoidance of double taxation.

DTAs of San Marino: 19 Signed Agreements

San Marino signed DTAs which already came info force with the following jurisdictions (for agreements which came into force after 1 January 2013 the date of coming into force is given in brackets):

 Austria
 Barbados (Aug 2013)
 Belgium
 Cyprus
 Georgia (Apr 2013)
 Greece (Apr 2014)
 Hungary
 Italy (Oct 2013)
 Liechtenstein
 Luxembourg
 Malaysia
 Malta
 Romania
 Saint Kitts and Nevis (Feb 2014)
 Seychelles (May 2013)

There are also several agreements between San Marino and other jurisdictions which were signed but haven't yet come into force (for agreements signed after after 1 January 2013 of signing the agreement is given in brackets):

 Portugal
 Qatar (Mar 2013)
 Singapore (Dec 2013)
 Vietnam (Feb 2013)

Information Exchange

There are 3 ways for jusrisdictions to exchange information on tax matters:

  • spontaneously;
  • on request;
  • automatically.

Spontaneous exchange of information is provision of information that is forseeably relevant to another party without a request being previously sent.

Tax Information Exchange Agreements (TIEAs) enable exchange of information on request relating to a specific tax investigation, either criminal or civil.

Automatic information exchange allows jurisdictions to exchange information automatically, without having a specific tax investigation.

Exchange on Request: 29 Signed Agreements

San Marino signed TIEAs which already came info force with the following jurisdictions (for agreements which came into force after 1 January 2013 the date of coming into force is given in brackets):

 Andorra
 Argentina
 Australia
 Bahamas
 Canada
 China (Apr 2013)
 Czech Republic
 Denmark
 Faroe Islands
 Finland
 France
 Germany
 Guernsey
 Iceland
 India (Aug 2014)
 Ireland (May 2013)
 Monaco
 Netherlands
 Norway
 Poland (Feb 2013)
 Samoa
 South Africa
 Spain
 Sweden
 United Kingdom

There are also several agreements between San Marino and other jurisdictions which was signed but haven't yet come into force (for agreements signed after 1 January 2013 of signing the agreement is given in brackets):

 Greenland
 Indonesia (Sep 2013)
 Switzerland (May 2014)
 Vanuatu

Automatic Exchange: Starts in September 2017

San Marino signed the automatic information exchange agreement on 29 October 2014 and committed to start the automatic information exchange in September 2017.

Automatic Excnange: 49 Bilateral Agreements to Receive Information

San Marino has signed bilateral agreements with 49 jurisdictions to automatically receive information:

 Argentina
 Australia
 Austria
 Belgium
 Bonaire, Saint Eustatius and Saba
 Bulgaria
 Canada
 Colombia
 Croatia
 Cyprus
 Czech Republic
 Denmark
 Estonia
 Faroe Islands
 Finland
 France
 Germany
 Gibraltar
 Greece
 Guernsey
 Hungary
 Iceland
 India
 Ireland
 Isle of Man
 Italy
 Japan
 Jersey
 Korea, Republic of
 Latvia
 Liechtenstein
 Lithuania
 Luxembourg
 Malta
 Mexico
 Monaco
 Netherlands
 New Zealand
 Norway
 Poland
 Portugal
 Romania
 Seychelles
 Slovakia
 Slovenia
 South Africa
 Spain
 Sweden
 United Kingdom

Automatic Excnange: 55 Bilateral Agreements to Send Information

San Marino has signed bilateral agreements with 55 jurisdictions to automatically send information:

 Anguilla
 Argentina
 Australia
 Austria
 Belgium
 Bermuda
 Bonaire, Saint Eustatius and Saba
 British Virgin Islands
 Bulgaria
 Canada
 Cayman Islands
 Colombia
 Croatia
 Cyprus
 Czech Republic
 Denmark
 Estonia
 Faroe Islands
 Finland
 France
 Germany
 Gibraltar
 Greece
 Guernsey
 Hungary
 Iceland
 India
 Ireland
 Isle of Man
 Italy
 Japan
 Jersey
 Korea, Republic of
 Latvia
 Liechtenstein
 Lithuania
 Luxembourg
 Malta
 Mexico
 Monaco
 Montserrat
 Netherlands
 New Zealand
 Norway
 Poland
 Portugal
 Romania
 Seychelles
 Slovakia
 Slovenia
 South Africa
 Spain
 Sweden
 Turks and Caicos Islands
 United Kingdom

Further Information

FATCA

Foreign Account Tax Compliance Act (FATCA) which became law in the United States in March 2010, focuses on reporting made by foreign financial institutions about financial accounts held by US taxpayers or foreign entities in which US taxpayers hold a substantial ownership interest. The FATCA-reporting is facilitated by Intergovernmental Agreements (IGAs).

FATCA Status in San Marino
IGA agreed on 30 June 2014, Model 2

San Marino agreed in substance to use FATCA on 30 June 2014 (Intergovernmental Agreement Model 2): the text of the IGA has not been released and financial institutions operating in San Marino are allowed to register on the FATCA website consistent with the treatment of having an IGA in effect provided that San Marino continues to demonstrate firm resolve to sign the IGA as soon as possible.

Further Information