San Marino ratifies its decree on the entry and stay of foreigners with amendments

According to local press reports of 23 September 2026, the Great and General Council ratified Delegated Decree No 115 of 2026 ("Legge sull'ingresso e la permanenza degli stranieri in Repubblica"). The foreign income of atypical residents is subject to a substitute tax equal to 7% of the "netto frontiera", with a minimum of €10,000 and a maximum of €100,000 per tax year. The amendment makes clear that the tax is due even where the income is not taxable in San Marino under a double taxation treaty.

Under the amended Article 2-bis on economic residence, the entrepreneur must employ a San Marino resident rather than exclusively a San Marino citizen, and the obligation to hire a second employee within three years has been removed. The article also updated the amounts required of investors; the reports do not give the figures. The government (Congresso di Stato) will report to the Foreign Affairs Committee on 31 January and 31 July on residence types, economic residences granted and the checks on commitments made.