🇸🇲 San Marino
Europe & Central Asia ·
San Marino has implemented statutory country-by-country reporting requirements. The country does not have controlled foreign company rules or interest limitation rules. Tax revenue accounted for 17.3% of GDP in 2023, based on central government data.Auto-generated summary of the verified data below; every fact traces to a source on this page.
Enforcement powers
Crypto-asset reporting Partial / committed
Listed by the OECD Global Forum as committed to implement the Crypto-Asset Reporting Framework in time for first exchanges by 2027 (list updated 17 June 2025).
“Romania, San Marino, Slovak Republic”
Source: OECD Global Forum — Jurisdictions committed to implement the Crypto-Asset Reporting FrameworkOfficial source · quote machine-verified 2026-08-25
Controlled foreign company (CFC) rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Interest limitation rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Country-by-country reporting Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).
“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 2 data points
| Is there a controlled foreign company rule in place? · Regime 1 | No |
| Is there a controlled foreign company rule in place? · Not applicable | No |
Interest limitation — 2 data points
| Is there an interest limitation rule in place? · Rule 1 | No |
| Is there an interest limitation rule in place? · Not applicable | No |
Country-by-country reporting — 4 data points
| Is there a country-by-country reporting law in place? | Yes |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | EUR 750 million |
| Headquarter jurisidiction filing required from | 01-Jan-19 |
IP regimes — 18 data points
| Further information · Regime 1 | Qualifying assets refers to industrial patents, granted or in the course of being granted, which include patents for inventions, such as biotechnological inventions and relevant supplementary protection certificates, patents for utility models, as well as patents and certificates on plant varieties; designs and models, protected by law and deriving from research and development activities; softwar… |
| Further information · Regime 2 | Qualifying assets refers to industrial patents, granted or in the course of being granted, which include patents for inventions, such as biotechnological inventions and relevant supplementary protection certificates, patents for utility models, as well as patents and certificates on plant varieties; designs and models, protected by law and deriving from research and development activities; softwar… |
| Further information · Regime 3 | Qualifying assets refers to industrial patents, granted or in the course of being granted, which include patents for inventions, such as biotechnological inventions and relevant supplementary protection certificates, patents for utility models, as well as patents and certificates on plant varieties; designs and models, protected by law and deriving from research and development activities; softwar… |
| Regime name · Regime 1 | New companies regime provided by art. 73, law no. 166/2013 |
| Regime name · Regime 2 | IP regime |
| Regime name · Regime 3 | IP regime |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 1 | Abolished |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 2 | Abolished |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 3 | Not harmful |
| Asset types that can qualify for the IP regime · Regime 1 | Patents, Software |
| Asset types that can qualify for the IP regime · Regime 2 | Patents, Software |
| Asset types that can qualify for the IP regime · Regime 3 | Patents, Software |
| Tax rate that would otherwise apply · Regime 1 | 17.00% |
| Tax rate that would otherwise apply · Regime 2 | 17.00% |
| Tax rate that would otherwise apply · Regime 3 | 17.00% |
| Reduced tax rate that applies under the IP regime · Regime 1 | 8.50% |
| Reduced tax rate that applies under the IP regime · Regime 2 | 0.00% |
| Reduced tax rate that applies under the IP regime · Regime 3 | 0.00% |