🇸🇲 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 2026-10-12
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
Mandatory disclosure rules  No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there mandatory disclosure rules requiring the disclosure of Common Reporting Standards (CRS) avoidance or aggressive tax planning arrangements? · Not applicable" — No”
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 and CbCR rules. IP regimes are covered in their own section below.
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
The OECD publishes this table without a reference year, so these entries are undated at source.
| 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
Patent-box and innovation-box preferential rates for qualifying IP income, as curated by the OECD Corporate Tax Statistics / QDD database. Each regime is shown as most recently reported; regimes the OECD records as abolished are kept and marked, not dropped.
New companies regime provided by art. 73, law no. 166/2013Abolished
As most recently reported for 2026.
Qualifying income was taxed at 8.50% under this regime, against a headline rate of 17.00%.
Qualifying assets: Patents, Software.
OECD Forum on Harmful Tax Practices assessment: Abolished.
IP regimeAbolished
As most recently reported for 2026.
Qualifying income was taxed at 0.00% under this regime, against a headline rate of 17.00%.
Qualifying assets: Patents, Software.
OECD Forum on Harmful Tax Practices assessment: Abolished.
IP regime
As most recently reported for 2020.
Qualifying income is taxed at 0.00% under this regime, against a headline rate of 17.00%.
Qualifying assets: Patents, Software.
OECD Forum on Harmful Tax Practices assessment: Not harmful.