San Marino Introduces Country-by-Country Reporting

; posted on
January 29th, 2019

On 25 January 2019, San Marino introduced gazette Delegate Decree No. 18/2019. The Delegate Decree, which has entered into force, reveals a country-by-country (CbC) reporting obligation starting from fiscal year 2019.

The Scope

The CbC reporting should be submitted by multinational groups (MNE groups) which are an MNE group’s ultimate parent entity, resident in San Marino for tax purposes (by December 31 of the year following the reporting fiscal year) with a total consolidated group revenue of EUR 750 million or more. Under certain circumstances, the reporting obligations may also be shifted to a subsidiary of the group or to a permanent establishment.

The competent authorities will then exchange the submitted CbC reports with the authorities of all other jurisdictions where the group operates to assess the risk related to tax base erosion and transfer pricing. The qualifying exchange of information agreement applies, by March 31 of the second year following the reporting fiscal year. By way of exception, the deadline for the first reporting fiscal year has been postponed until June 30, 2021.

The Report

The CbC reports must be prepared according to the models laid out in the Delegate Decree (Annex A) and include the following information:

  • aggregate information relating to the amount of revenue, profit or loss before income tax, income tax paid, income tax accrued, stated capital, accumulated earnings, number of employees and tangible assets other than cash or cash equivalents with regard to each jurisdiction in which the MNE group operates; and
  • identification of each constituent entity of the MNE group set out the relevant jurisdiction of tax residence and, where different, the jurisdiction under the laws of which it is organized, and the nature of its main business activity or activities.


Penalties will be imposed, a minimum of 10,000.00 euros to a maximum of 50,000.00 euros, in the case of omitted or late filing and filing of inaccurate information.

Source: San Marino Government (Italian)

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