San Marino updates economic-residence rules and sets a transition for existing holders
Decree 150, published on 5 October, sets out ownership, employment and security requirements and clarifies the annual minimum tax for a separate residence category.
San Marino published Delegated Decree 150/2026 on 5 October, when the parliamentary record says it entered into force. The final text incorporates amendments ratified on 23 September, rewriting economic-residence rules and clarifying substitute tax and family coverage under the separate preferential-tax residence category.[1][2]
An economic-residence applicant must directly own at least 51% of a company. The employment condition is at least 1 full-time permanent employee who is a Sammarinese resident, or 2 permanent part-time employees resident in San Marino whose combined hours equal a full-time position. Applicants and accompanying family members do not count. The annual ceiling is 50 principal applicants, excluding family members, and other statutory conditions still apply.[1]
Initial security is €75,000, rising within 2 years of residence to €150,000 or replaced by property purchased for at least that amount. The property must already exist when the transaction is completed, be used as the business address or the beneficiary’s home within 12 months of residence being granted, and carry a registered privilege in favour of the state. Non-compliance can lead to revocation.[1]
Existing economic-residence holders must comply within 6 months of the 23 September ratification. Consolidation of residence after 10 years still requires an application and checks; it is not automatic.[1]
For the separate preferential-tax residence category, the 7% substitute tax uses the statutory “netto frontiera” basis for net foreign income. Each tax year during residence carries a €10,000 minimum and €100,000 maximum; the minimum remains payable even when a tax treaty makes the foreign income non-taxable in San Marino. It also covers family members whose residence is extended, except tax-dependent children, who enter the regime from the tax year after dependency ends. The final provision specifies application from tax year 2026.[1]
Official sources
This article provides general information. Individual applications are subject to the applicable rules and the competent authority’s assessment.