San Marino

{"ftc_utility":"high","fbar_trigger_notes":"US expats residing in San Marino are required to maintain a local bank account for salary and utility payments. San Marino uses the euro (EUR). Any San Marino bank account with an aggregate balance exceeding USD 10,000 at any point in the calendar year triggers FBAR filing on FinCEN Form 114. FATCA compliance applies as San Marino signed a Model 1 IGA with the US.","ftc_utility_reason":"San Marino imposes a progressive income tax on worldwide income of residents at rates up to 40%. US expats paying San Marino income tax can use the Foreign Tax Credit to offset US tax liability dollar-for-dollar on the same income, reducing or eliminating US tax owed. The FTC is generally more advantageous than the FEIE for higher earners subject to the upper San Marino brackets.","presence_day_count_notes":"San Marino is a microstate fully surrounded by Italy. US citizens typically enter via Italy with no formal San Marino border stamp. There is no Schengen-specific day count concern for San Marino itself, but residency registration (residenza) is required to establish domicile. Physical presence tracking is straightforward once legal residency is established. The 330-day rule is practically achievable for residents who register properly.","typical_qualifying_method":"either","housing_exclusion_available":true,"physical_presence_test_applies":true,"estimated_housing_exclusion_usd":18000,"local_tax_rate_on_earned_income":0.25,"bona_fide_residence_test_applies":true}

{"pension_income":{"notes":"Foreign pension income received by San Marino residents is taxed under the standard progressive personal income tax brackets. The effective rate depends on total income. Partial deductions may be available for contributions previously taxed, but rules are not codified in a US-specific treaty context.","tax_rate":null,"locally_taxed":true},"social_security":{"notes":"No tax treaty exists between the US and San Marino. US Social Security benefits received by a San Marino resident are not protected and may be included in taxable income under the progressive scale. San Marino does have a totalization-style arrangement tied to its EU-adjacent labor agreements but not a formal US-SMR social security totalization agreement.","locally_taxed":true,"treaty_protection":false},"roth_distributions":{"notes":"Without a US-San Marino tax treaty, Roth IRA qualified distributions have no recognized exempt status locally. San Marino tax authorities would likely treat them as foreign income subject to the standard progressive rates. The US after-tax character of Roth funds is not recognized under San Marino domestic law.","locally_taxed":true},"us_401k_ira_distributions":{"notes":"San Marino and the United States do not have a bilateral income tax treaty. US 401(k) and IRA distributions received by a San Marino resident are treated as foreign-source pension or income and subject to the progressive personal income tax at ordinary rates up to 40%. No treaty exemption or reduced rate applies.","tax_rate":null,"locally_taxed":true,"treaty_protection":false}}

{"rate":0.4,"notes":"San Marino does not maintain a separate capital gains tax regime for individuals. Gains from asset disposals are generally folded into ordinary income and taxed at the standard progressive rates, with the top marginal rate at 40%.","details":{"tax_type":"Capital Gains Tax","country_name":"San Marino","country_iso_code":"SMR","source_references":["San Marino Law No. 91/1984 and subsequent amendments on income taxation","OECD tax profile notes on San Marino","General knowledge of San Marino fiscal system"],"last_verified_date":"2026-06-03","general_description":"San Marino taxes capital gains as ordinary income under the general progressive personal income tax (IRPEF equivalent). There is no standalone CGT at a flat rate. Corporate entities may be subject to a separate corporate tax on gains at the standard corporate rate.","corporate_capital_gains":{"rate":0.17,"tax_treatment":"Capital gains realized by corporations resident in San Marino are generally taxed under the corporate income tax at the flat rate of 17%. Participation exemptions may apply in certain qualifying holding structures."},"individual_capital_gains":{"rate":0.4,"tax_treatment":"Individual capital gains are taxed as ordinary income at the applicable progressive personal income tax bracket. The top rate is 40% on income above EUR 100,000. No separate flat CGT rate exists for individuals."}}}

{"notes":"San Marino applies a withholding tax on dividends distributed to individuals. The standard domestic withholding rate is 5% on dividends received from San Marino-resident companies, applicable to both resident and non-resident shareholders. This rate is lower than the general income tax brackets and functions as a final tax for individuals.","rates":[{"rate":0.05,"type":"withholding","notes":"Standard withholding on dividends from San Marino-resident companies to individuals. Functions as a final tax. San Marino has a limited tax treaty network, so non-residents should check whether a bilateral treaty modifies this rate."}]}