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San Marino TIN number guide

Social Security Number (SSI Number)

The Social Security Number (SSI Number) identifies all individuals in San Marino. It is issued by the Social Security Institute

SSI consists of block of digits assigned in sequence, but they do not contain any information on taxpayers, such as name and surname, address, age or gender. It consists of upto 9 digits. Eg: 999999999

The Social Security Number (SSN) is prominently displayed on the front side of the identity card issued by the Vital Statistics Office. It is positioned adjacent to the holder's photo, located on the right-hand side of the card.

Tax Registration Number (COE)

The Tax Registration Number (COE) is issued to all legal entities in San Marino and is issued by the Office of Industry, Handicraft and Trade or the Labour Office for the Tax Registration Number (COE). It is locally known as Codice Operatore Economico (COE).

COE consists of 7 digits. It is preceded by the letters SM followed by 5 digits. Eg: SM99999

The Tax Registration Number (COE) is displayed on the Certificate of License issued by the Office of Industry, Handicraft, and Trade.


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Frequently Asked Questions

Does a foreign company need a COE to operate in San Marino, and what triggers the permanent establishment threshold?

A foreign company or individual that carries out economic activity in San Marino for more than 180 days in a calendar year is treated as a San Marino economic operator via permanent establishment and must obtain a COE (Codice Operatore Economico). Below 180 days, a fixed-term activity licence suffices. Either way, foreign applicants must appoint a locally resident agent — a San Marino-based professional with a registered address — who assumes the same rights and duties as a sole director. Operating beyond the 180-day threshold without COE registration exposes the operator to sanctions from the Ufficio Tributario. [1] [2]

How does San Marino's corporate tax rate compare to Italy's, and does it still trigger Italy's CFC rules?

San Marino's standard corporate income tax (IGR) is 17%, falling above the 15% minimum effective tax rate threshold introduced under Italy's 2024 CFC simplification reform. This means a San Marino subsidiary controlled by an Italian resident company is not automatically a CFC subject to look-through taxation in Italy — provided the subsidiary conducts a genuine economic activity supported by staff, assets, and premises. However, Italian residents who set up a San Marino entity purely to hold passive income with no real substance still risk a CFC challenge; the Italian Revenue Agency allows advance ruling requests to obtain certainty on substance. San Marino was removed from Italy's tax blacklist in 2014. [3] [4]

San Marino uses a monofase import tax, not EU VAT — what does this mean for a foreign B2B supplier selling goods into San Marino?

San Marino is not an EU member and does not apply EU VAT. Historically it used the monofase system — a single-stage import-level tax (standard rate 17%) collected at the border rather than along the supply chain. A new consumption tax called IGC (Imposta Generale sui Consumi) is being phased in to align with VAT principles, but during the transition foreign suppliers selling goods into San Marino do not charge EU VAT; instead, the import tax is assessed at the San Marino customs border. Foreign suppliers therefore do not need to register for a San Marino COE solely to sell goods to San Marino buyers — the tax obligation falls on the importer. San Marino's customs union with the EU means goods in free circulation in the EU enter San Marino without tariffs. [5] [6]

How must an Italian company report purchases from a San Marino supplier — and what is document type TD28?

Italian buyers purchasing goods from San Marino face a specific e-invoicing rule. San Marino suppliers can issue either an electronic invoice via the HUB-SM platform (routed through Italy's SDI system) or a paper invoice showing VAT. When a San Marino supplier issues a paper invoice showing VAT, the Italian buyer must self-report the purchase by filing a TD28 (Acquisti da San Marino con IVA — paper invoice) document type into the SDI. Failure to submit TD28 leaves the Italian buyer's deduction at risk during an audit. When the San Marino supplier uses HUB-SM to issue an electronic invoice, the Italian buyer receives it through the normal SDI flow and no separate TD28 is required. [7] [8]

Can a non-San Marino resident own 100% of a San Marino company, or is a local shareholder required?

Non-residents may own shares in San Marino companies, but the rules differ by sector. For general commercial trading companies (società commerciali), at least 51% of shares must be held by a San Marino resident — a significant constraint for foreign entrepreneurs. For non-trading entities and holding structures, 100% foreign ownership is permitted. Regardless of shareholding, foreign operators must appoint a locally resident agent who serves as the address for service and assumes director-level obligations. This residency requirement for trading activities is a common surprise for foreign investors expecting fully remote ownership and is enforced by the Office of Industry, Handicraft and Trade at the time of COE issuance. [1] [2]