San Marino has published Delegated Decree No. 68 of 25 April 2019, which provides for the amendment and ratification of Delegated Decree No. 18 of 25 January 2019 on the automatic exchange of Country-by-Country (CbC) reports ({News-2019-02-01/A/5-previous coverage}).

Overall, the CbC reporting requirements provided in Decree No. 68 are unchanged from those provided in Decree No. 18, although Article 9 on penalties has been amended. This includes that separate from the penalty of EUR 10,000 to EUR 50,000 for failing to submit a CbC report by the deadline or for submitting incomplete or incorrect information, a penalty of EUR 8,000 will apply for late submission, with the penalty reduced:

• by 50% if the delay is 15 days or less; or
• by 30% if the delay is more than 15 days but less than 30 days.

Further, it is provided that the EUR 10,000 to EUR 50,000 penalty will apply where a CbC report is submitted after 31 March of the second year following the reporting period. San Marino's CbC reporting requirements apply from the 2019 tax period, with a standard deadline of 31 December of the year following the tax period.

Delegated Decree No. 68 entered into force on 25 April.