San Marino

Transfer Pricing in San Marino

San Marino transfer pricing for tax year 2026: the normal-value rule for dealings between a company and companies that control it, are controlled by it or share its controller (IGR article 46(4)), the related-party rule for sole traders and professionals (article 30(4-bis)), the article 6 definition of normal value, the control and significant-influence definitions, downward adjustments only after a definitive foreign arm's-length adjustment or a mutual agreement, and international advance agreements under Delegated Decree 116/2026 (fees of EUR 10,000, 30,000 or 50,000 by group turnover, halved for unilateral agreements and renewals, binding for five tax periods). Use for San Marino intercompany pricing, related-party adjustments, APA application and corresponding adjustment questions. Comparable searches, documentation files and mutual agreement procedures need the actual case.