San Marino’s parliament approved amendments that tighten the substitute‑tax floor for atypical residents at €10,000 and simplify the hiring requirement for the entrepreneur‑residency programme.
7 % substitute tax floor
- The substitute tax on foreign‑source income for atypical residents remains 7 % of the net amount after foreign tax (“netto frontiera”).
- A mandatory minimum of €10,000 and a ceiling of €100,000 apply per tax year.
- The tax is now due even when a double‑taxation treaty would otherwise exempt the income in San Marino.
- The floor means any holder with foreign income below roughly €143 000 pays €10 000; those with income above about €1.43 million are capped at €100 000.
The change is presented as a “flat‑price” entry, preventing the regime from being used as a low‑cost residence certificate for individuals with little foreign income.
Entrepreneur residency eased
- Applicants must own at least 51 % of a San Marino company.
- Only one full‑time employee is now required, instead of the previous 1‑3 hires.
- The employee may be any San Marino resident, not necessarily a citizen.
- A guarantee of €75 000 must be posted, rising to €150 000 within two years (achievable, for example, through a property purchase).
- An annual cap of 50 new economic residencies is imposed.
- Residency extends to the applicant’s spouse, dependent children (up to age 25), and children with disabilities; beneficiaries cover their own healthcare until the status consolidates after ten years.
The previous rules required a second hire by the third year; that obligation has been removed.
Practical considerations
- The route is aimed at owner‑managed businesses that can operate with a single local employee, such as consultants, small trading or e‑commerce firms, and professional services.
- The €75 000‑to‑€150 000 guarantee is described as “meaningful but not prohibitive.”
- Applicants who continue to live primarily in Italy (e.g., Rimini) may still face Italian residency and corporate‑management rules, which consider physical presence and the centre of personal life.
- The 50‑per‑year limit signals selectivity rather than a mass‑market programme.
Outlook
- The amendments are framed as “housekeeping” to resolve inconsistencies in overlapping laws.
- Further debate is expected on the broader residency chapter of San Marino’s EU association agreement, including the profile of residents the republic seeks and how commitments will be monitored.
- Reporting on granted residencies is now required twice a year (by 31 January and 31 July), addressing a previous shortfall in quarterly reporting.
These adjustments mark the second residency‑policy change in 18 months, following the April 2025 tightening of income and asset thresholds for foreign pensioners.
Source article: www.imidaily.com
