San Marino has published Law No. 94 of 24 June 2022 on changes to the budget for 2022. This includes amendments to the conditions for the new foreign financial assets held by individuals (imposta per il riequilibrio delle attività finanziarie estere - IRAFE). The IRAFE was introduced as part of the original budget measures for 2022 and is levied at a rate of 0.2% on qualifying foreign financial assets held directly or indirectly by an individual resident in San Marino. It was originally provided that the IRAFE applied to an individual who has been resident in San Marino for more than 5 continuous years, or not subject to a special tax regime on foreign income. Law No. 94 increases the residence requirement to more than 10 continuous years. It is also provided that the tax is not due if not exceeding EUR 10.
Law No. 94 has also replaced article 22-bis of Law No. 71/2013 regarding residence for economic reasons, including new conditions for such residence. Under the new article 22-bis, individuals may qualify for residence for economic residence if they undertake an economic activity through a company formed in San Marino where the following conditions are met:
Lastly, Law No. 94 has postponed the deadline for individuals to submit their annual tax return for tax year 2021 and the related payment from 30 June 2022 to 31 July 2022.