{"id":"san-marino-pensioner-residence","name":"San Marino Atypical Residence for Pensioners","type":"RBI","status":"operational","country":"San Marino","country_code":"SM","url":"https://www.mirabelloconsultancy.com/immigration/san-marino-pensioner-residence","min_investment":{"amount":null,"currency":"EUR","route":"Gross income of at least EUR 120,000 a year and EUR 300,000 of the applicant's own movable assets held in San Marino banks, with a 6% flat substitute tax on pension income for ten years (Law 118/2010 art. 16-quater; Law 64/2025 art. 2). Proof of income and assets, not a payment to the State"},"qualification_basis":"financial_means","investment_routes":null,"family_pricing":null,"processing_time":null,"processing_time_note":"The Foreign Affairs Commission must decide within 120 days of a complete file (art. 16-quater(4)) and its decision cannot be appealed. A provisional permit of up to 6 months is available while the file proceeds (art. 16-quinquies). After the grant the applicant files the final lease or deed, a residence declaration and the bank transfer certificate. The full path (preliminary lease or purchase contract, bank account, apostilled documents, transfer of EUR 300,000) is not timed. Fee: EUR 1,000 non-refundable procedural fee (art. 16-quater(3); vademecum of 27 May 2025); other fees not read.","visa_free_count":null,"passport_index_rank":null,"key_destinations":null,"travel_access":null,"minimum_stay":"No minimum stay is fixed, but the residence needs habitual dwelling checked by the Gendarmeria, and the Civil Registrar revokes it when habitual dwelling has lapsed for more than six months (Law 118/2010 art. 17(5)(a)).","tax_note":null,"path_to_citizenship":"Not stated for this route in the texts read; San Marino citizenship law was not read.","highlights":["6% flat substitute tax on pension income for ten years; other foreign income follows the ordinary rules","Needs EUR 120,000 gross income and EUR 300,000 held in San Marino banks; capped at 249 new residences a year"],"atomic_answer":"San Marino's atypical residence for pensioners requires gross income of at least EUR 120,000 a year and EUR 300,000 of the applicant's own movable assets held in San Marino banks for the whole duration of the residence (Law 118/2010 art. 16-quater, as amended by Law 64/2025 art. 2). Pension income is taxed at a flat 6% substitute income tax for ten consecutive years, while other foreign income follows the ordinary rules (art. 16-quater(2); Law 166/2013 art. 13). The Foreign Affairs Commission decides within 120 days, new grants are capped at 249 a year, and habitual dwelling is checked, with revocation after more than six months away.","fees":null,"last_updated":"2026-10-11","data_freshness":null,"mirabello_index":{"composite":65,"rank_overall":null,"rank_in_type":null,"scores":{"stability":65},"confidence":0.14},"regulatory_status":{"fatf_list":null,"eu_tax_list":null,"us_sanctions":null,"oecd_crs_high_risk_scheme":false,"as_of":"2026-06","status":"not listed on FATF, EU tax, US OFAC, or OECD CRS-risk lists"},"processing_stages":null,"required_documents":null,"biometric_enrolment":null,"dependant_additions":null,"nationality_naturalisation":null,"retirement":{"route_name":"San Marino atypical residence for pensioners (6% substitute tax on pension income)","region":"Europe","tags":["retirement","passive-income"],"income_requirement":{"amount":120000,"currency":"EUR","period":"year","basis":"either","per_dependant":null,"note":"Gross income of at least EUR 120,000 a year is required together with, not instead of, EUR 300,000 of movable assets: since Law 64/2025 art. 2 (28 April 2025) the two tests are cumulative (the earlier alternative of EUR 50,000 income or EUR 300,000 assets was replaced). The applicant must be a pensioner, but the text does not tie the EUR 120,000 test to a pension type, and the Foreign Affairs vademecum accepts a tax return or documents showing the resources, so the basis is recorded as either. Family members can be added as secondary applicants (art. 16-quater(6), referring to art. 16(3-bis)); no extra income figure per dependant is set, only that applicant and relatives have sufficient means. (unverified)"},"net_worth_or_deposit_option":{"amount":300000,"currency":"EUR","kind":"savings_balance","required":true,"note":"Required in addition to the income test: movable assets (deposits or financial instruments) of at least EUR 300,000 held in the San Marino banking system for the whole duration of the residence, evidenced by a bank certificate of transfer filed after the grant. The assets stay the holder's own and are not paid to the State. The article's bans, duties and constraints cease on renunciation or after ten years from registration (consolidation); whether the EUR 300,000 lock-up is among them is not stated expressly. A non-refundable EUR 1,000 procedural fee absorbs stamp duties and office fees. (unverified)","source":"https://www.gov.sm/pub1/upav/dam/jcr:6fa3db64-e715-4c9a-a310-b480189446ff/L064-2025+All.pdf","kind_original":"banked_assets"},"stay_requirement":{"days_per_year":null,"max_continuous_absence_days":183,"stated_by_official_source":true,"rule":"No minimum stay is fixed, but the residence needs habitual dwelling checked by the Gendarmeria, and the Civil Registrar revokes it when habitual dwelling has lapsed for more than six months (Law 118/2010 art. 17(5)(a)).","note":"Tax residence is separate: registered residence, dwelling or centre of vital interests in San Marino for most of the tax period (Law 166/2013 art. 10(2))."},"foreign_income_tax":{"treatment":"partial","label":"Partial: some foreign income is taxed and some is not; read the note.","note":"Partial. Residents are taxed on worldwide income (Law 166/2013 arts. 1 and 10). Pension income of an atypical-pensioner resident can be settled by a flat 6% substitute IGR for ten consecutive years, whether or not a double tax treaty exists with the origin country (3% for former senior officials of international organisations with at least EUR 100,000 gross a year), paid in one sum by the IGR balance date; it covers pension income only, effects cease on missed or partial payment (90 days to cure) and revocation bars a new request (Law 118/2010 art. 16-quater(2) and (2-bis)). Other foreign income follows the ordinary rules: foreign dividends 3% of the net-of-foreign-tax amount, foreign bond interest 10% and foreign bank-account interest 13%, each by option (otherwise progressive IGR of 9% to 35%); gains within art. 41 are taxed at 10% separate tax, with an option for progressive taxation on foreign-source gains; foreign land and building income falls under the progressive scale (computation not read). (unverified)","source":"https://www.consigliograndeegenerale.sm/on-line/home/in-evidenza-in-home-page/documento17084094.html","tax_residence_caveat":"Tax follows tax residence, not the permit: the treatment applies once you are tax-resident there. Information, not tax advice."},"path_to_pr":"Registered residence with no expiry date in art. 16-quater, kept while the conditions hold; consolidated after ten years from registration, when the article's duties and bars lapse.","path_to_citizenship":"Not stated for this route in the texts read; San Marino citizenship law was not read.","processing_note":"The Foreign Affairs Commission must decide within 120 days of a complete file (art. 16-quater(4)) and its decision cannot be appealed. A provisional permit of up to 6 months is available while the file proceeds (art. 16-quinquies). After the grant the applicant files the final lease or deed, a residence declaration and the bank transfer certificate. The full path (preliminary lease or purchase contract, bank account, apostilled documents, transfer of EUR 300,000) is not timed. Fee: EUR 1,000 non-refundable procedural fee (art. 16-quater(3); vademecum of 27 May 2025); other fees not read.","official_source":"https://www.gov.sm/pub1/upav/dam/jcr:6fa3db64-e715-4c9a-a310-b480189446ff/L064-2025+All.pdf","legal_basis":"Law 28 June 2010 n.118 (entry and stay of foreigners), art. 16-quater (atypical residence for pensioners), inserted by art. 70 of Law 23 December 2020 n.223 and amended by Decree-Law 110/2021 art. 3-ter, Delegated Decree 26/2025, Law 28 April 2025 n.64 art. 2 (EUR 120,000 and EUR 300,000 thresholds) and Delegated Decree 77/2025 (annual ceiling of 249), with arts. 16-quinquies and 17 (provisional permit, bars and revocation); Law 16 December 2013 n.166 (general income tax, IGR) arts. 1, 10, 11, 13 and Annex C art. C1, art. 13 as replaced by Law 12 November 2025 n.141. Coordinated text of Law 118/2010 updated to 3 June 2025.","as_of":"2026-10-11"},"golden_retirement":{"standard":"Mirabello Golden Retirement Index","applies_to":"San Marino atypical residence for pensioners (6% substitute tax on pension income)","tier":"partial","tier_label":"Partial: meets most of the standard, with one gap","score":60.5,"confidence_grade":"B","renewal_category":"never: permanent from grant","renewals_before_pr":0,"pillars":{"tax":12,"presence":14,"financial":5.5,"durability":11,"processing":4,"healthcare":3,"family_work_mobility":3,"pr_citizenship":8},"reasons":["The income must be transferred to, or held in, the country"],"as_of":"2026-10-11","methodology_version":"1.1.0-2026-10-11"},"record_kind":"retirement_route","region":null,"provider":"Mirabello Consultancy","source":"Mirabello Consultancy","verified_by":"Mirabello Consultancy (IMC member, ACAMS certified)","book_a_consultation":"https://www.mirabelloconsultancy.com/contact-us-for-your-free-consultation","terms":"https://www.mirabelloconsultancy.com/ai","disclaimer":"Provided by Mirabello Consultancy Ltd. for general information only, indicative and subject to change without notice; not legal, financial, tax, or immigration advice, nor an offer or solicitation. Programmes are operated and governed solely by the respective sovereign governments. No warranty of accuracy or completeness; Mirabello accepts no liability for reliance on this information. © Mirabello Consultancy Ltd. This data and its selection, structure and provenance are Mirabello's proprietary compilation — permitted for interactive, attributed use only; systematic bulk extraction, scraping, or redistribution to rebuild a competing dataset is prohibited (acceptable-use terms: https://mcp.mirabelloconsultancy.com/v1/terms). Terms: https://www.mirabelloconsultancy.com/ai","data_updated":"2026-10-12T19:35:18.892Z"}