The foreign policy of the Republic of San Marino is based on a traditional neutrality defined as "active" on account of its constant involvement in international affairs. San Marino maintains official relations with 151 countries and is a member State of the majorInternational Organisations, such as the United Nations Organization and its funds, programs and specialized agencies - including IMF, World Bank and WHO -, OSCE, Council of Europe - including GRECO and MONEYVAL -, OECD's Global Forum on Transparency and Exchange of Information in Tax Matters.
DOUBLE TAXATION AGREEMENTS AND AGREEMENTS FOR THE PROMOTION AND PROTECTION OF INVESTMENTS.
The important commitment of the country towards the adjustment to the highest international standards of transparency led to the conclusion of an extensive network of tax agreements; at present, 24 Agreements on the Avoidance of Double Taxation (DTAs) in compliance with OECD standards, as well as 8 Agreements for the Promotion and Protection of Investments (PPI) are in force.
In addition, 30 Tax Information Exchange Agreements (TIEAs) are presently in force.
List of DTT Agreements in force
In 2013, San Marino signed the multilateral OECD and Council of Europe Convention on Mutual Administrative Assistance in Tax Matters, which entered into force for San Marino on 1 December 2015. Click here to see the document. On 29 October 2014, San Marino signed, together with 50 other jurisdictions, the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Information, thus joining the Early Adopters Group, i.e. the group of jurisdictions that apply the new standards as of 2017.
In July 2018, the Republic of San Marino was rated as Compliant by the Peer Review Group of the Global Forum on Transparency and Exchange of Information for Tax Purposes.
In October 2018 San Marino signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports, in compliance with the provisions of the OECD in the fight against Base Erosion and Profit Shifting - BEPS. Click here to see Decree-Law no. 76 of 28 June 2018.
In Febrauary 2019, the EU Finance Ministers fully promoted the Republic of San Marino as a "fully cooperative country for tax purposes". Such decision was based on compliance with tax transparency and fair taxation criteria and with OECD measures.
The current AML/CFT regime complies with the recommendations of the Financial Action Task Force (FATF) and with the relevant directives and regulations of the European Union.
San Marino is not a member State of the European Union. The relations between San Marino and the EU are based on a Cooperation and Customs Union Agreement in force since 2002. Negotiations are under way for the conclusion of an association agreement with the European Union, aimed at ensuring - for the matters covered by the future agreement - the full equivalence of the Republic with the Member States.
The new Monetary Agreement between San Marino and the EU was signed in 2012 and in February 2014 San Marino was included in the Single Euro Payments Area (SEPA).
An "Agreement between the European Union and the Republic of San Marino on the automatic exchange of financial account information to improve international tax compliance" was signed on 8 December 2015 and became effective in 2016. This Agreement, which is a Protocol amending the 2004 Agreement on Taxation of Savings Income, incorporates the Global Standard on Automatic Exchange of Financial Information adopted by the OECD.
The Protocol amending the Agreement between the European Community and the Republic of San Marino providing for measures equivalent to those laid down in Council Directive 2003/48/EC on taxation of savings income in the form of interest payments entered into force on 1 June 2016. Click here for additional information.
San Marino joined the Group of States of the Council of Europe against Corruption (GRECO) in August 2010. Participation in GRECO and the attention paid to corruption form part of the strong commitment of San Marino to aligning domestic legislation and practices with international standards in the fight against money laundering and terrorist financing, exchange of information for tax purposes and transparency of the economic and financial system.
Due to its geographical position as an enclave of the Italian Republic, San Marino’s institutional and economic relations with Italy have always been particularly important.
The numerous bilateral agreements in force testify to the constant and excellent relations. Among these, particularly important are the Double Taxation Agreement of 21 March 2002, the relevant Amending Protocol of 13 June 2012 and the Economic Cooperation Agreement of 31 March 2009, which covers various sectors. Click here for additional information.