Italy Takes San Marino Off Blacklist

by Ulrika Lomas, Tax-News.com, Brussels

17 February 2014

On February 12, the Italian Minister of the Economy and Finance Fabrizio Saccomanni signed a decree that definitively removed San Marino from the "black list" of countries Italy considers to be tax havens.

In a statement, the Ministry said that the Italian Government had recognized San Marino's desire for its removal from the list as soon as possible, and had therefore made it a priority to complete the Italian domestic procedures that were necessary before the decree could be issued. The removal is being seen as a "fundamental step towards the full normalization of economic and financial relations between the two countries."

The factor which had meant, above all, that Italy could make a positive ruling on San Marino's standing was the ratification, on October 3 last year, of the double taxation agreement (DTA) between the two countries. Apart from provisions for reduced withholding taxes on dividends, royalties and interest, the DTA contains the most recent internationally-agreed framework for the exchange of tax information and the overcoming of bank secrecy.

However, in another positive move in Italian eyes, San Marino has also been able to change its internal regulations to guarantee transparency within its economic system. Its Government has, for some time, been working to reduce the evasion of Italian taxes through its territory. Another DTA provision therefore introduced San Marino's obligation to monitor the movement of capital between Italy and San Marino, as well as the setting up of companies that have an interest, for example, in the profits or dividends of Italian companies.

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