San Marino

San Marino: San Marino Decree 144: Telematic Revenue Certification for Smac Merchants

Effective 1 January 2027, San Marino’s Decree Delegated No. 144 (24 September 2026) makes the telematic certification of revenues mandatory for merchants participating in the Smac Card circuit. The decree implements the combined reading of Article 12 of Law No. 166/2013 and subsequent amendments, establishing the technical specifications, transmission deadlines, and cost-sharing mechanisms for the

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San Marino: San Marino E-Invoicing Reg 28: Rules for Domestic B2B

On 10 September 2026, San Marino enacted Regulation No. 28 establishing the technical and procedural rules for the preparation, transmission, and receipt of electronic invoices between San Marino economic operators. This regulation operationalizes the mandatory domestic B2B e-invoicing framework, defining the data formats, transmission channels, and compliance obligations for taxpayers. The rules aim to align

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San Marino: Italy Supreme Court: Specific Motivation for Bank Investigations

On 21 September 2026, the Italian Court of Cassation (Supreme Court) issued a landmark ruling (referenced in Il Sole 24 Ore) changing the orientation on authorizations for bank investigations in tax matters. The Court held that a generic reference to the investigative hypothesis is insufficient; the prosecutor must provide a specific, detailed motivation linking the

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San Marino: San Marino TFR Tax for Cross-Border Workers: Annual Payout Rules

An article published on 7 September 2026 in Il Sole 24 Ore addresses the tax treatment of Trattamento di Fine Rapporto (TFR) severance payments made annually to Italian cross-border workers employed in San Marino. Unlike the standard lump-sum payment at termination, annual TFR payouts trigger distinct withholding tax obligations under the Italy-San Marino tax treaty

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San Marino: San Marino Extends Fuel Excise Cut: 10-Cent Reduction Until Oct 31

On 24 September 2026, San Marino issued Decree-Law No. 143, extending the extraordinary measures to contain fuel prices until 31 October 2026. The provision maintains the temporary reduction of 10 cents per liter on excise duties for gasoline and diesel, a policy initially introduced to mitigate the impact of international energy price volatility on consumers

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San Marino: San Marino Reg 29: DRP Filing Rules for ICEE Economic Indicator

Regulation No. 29, dated 16 September 2026, establishes the procedures for completing, submitting, and transmitting the Dichiarazione Reddituale e Patrimoniale (DRP) – the Income and Asset Declaration – for the purpose of calculating the ICEE (Indicatore della Condizione Economica Equivalente). The ICEE is a means-test indicator used to determine eligibility for social benefits, tax deductions,

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San Marino: San Marino Decree 137: Energy Cost Relief for Energy-Intensive Firms

Decree Delegated No. 137, issued on 14 September 2026, extends the extraordinary measures aimed at containing electricity and natural gas costs for energy-intensive enterprises operating in San Marino. The decree renews the tax credits, reduced network charges, and direct subsidies previously granted under earlier pandemic and energy crisis legislation. Eligible firms must meet the EU

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San Marino: Italy Tax Probes: Chat Messages Admissible with Prosecutor Decree

An article dated 30 September 2026 in Il Sole 24 Ore reports on the evolving use of instant messaging content (SMS, WhatsApp, Telegram) in tax criminal investigations. The Court of Cassation has clarified that chat logs are admissible as evidence only if acquired through a motivated decree by the public prosecutor (PM), respecting the constitutional

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San Marino: EU Small Parcel Tax Starts Nov 1: Customs Duty on Low-Value Imports

Starting 1 November 2026, the European Union will implement a new customs duty on low-value consignments (the “mini pacchi” tax) as part of the revised VAT e-commerce package. The measure eliminates the €22 VAT exemption threshold for imports, imposing VAT and, where applicable, customs duties on all goods entering the EU regardless of value. Italy

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San Marino: Italy Transfer Pricing: Understated Assets Risk Fraudulent Returns

A 16 September 2026 Cassation ruling, analyzed in Il Sole 24 Ore, highlights that systematically understating the value of assets transferred in intra-group transactions can elevate a transfer pricing adjustment to the level of a fraudulent tax declaration (dichiarazione infedele). The Court emphasized that transfer pricing manipulations are not mere valuation errors but intentional acts

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