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San Marino: Advance tax rulings and APAs for cross-border transactions

The new framework covers transfer pricing and other tax matters involving cross-border transactions.

October 15, 2026

The Government of San Marino on August 10, 2026, enacted Delegated Decree No. 116/2026, introducing unilateral, bilateral, and multilateral advance tax rulings, including advance pricing agreements (APAs), for cross-border transactions.

The decree covers:

  • Transfer pricing
  • Cross-border tax values
  • Permanent establishments
  • Profit attribution
  • Application of domestic law and income tax treaties to dividends, interest, royalties, and other income

The rulings generally bind the parties for five tax years. They may also apply retrospectively when the relevant factual and legal circumstances remain unchanged.
 

For more information, contact a KPMG tax professional:

Lorenzo Schippa | lschippa@kpmg.it

 

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