San Marino

Cross Border in San Marino

San Marino cross-border tax for 2026: residence of individuals and companies, San Marino-source income of non-residents, permanent establishment (including the three-month construction test), the October 2026 identification rule for non-residents, final withholding on payments abroad (13% interest, 11% qualifying bonds, 5% dividends to individuals, 20% professional and self-employed services, royalties and directors' fees, 3% artistic and sports performers, 10% equipment and vehicle rentals), bank interest rates, the Finance circular 1/2026 on interest paid to foreign banks and rentals paid to foreign operators (B2B withholding and B2C self-assessment at 18% by 31 July 2027), the corporate and personal foreign tax credit, treaty priority and international advance agreements. Use for San Marino withholding tax, non-resident income, payments to Italy or other countries, PE and foreign tax credit questions. Treaty rates need the actual treaty text.