San Marino Establishes New Rules for Advance Tax Rulings and Pricing Agreements for Entities Carrying Out International Activities

San Marino has established new procedures for advance tax rulings, including advance pricing agreements (APAs). The new procedures were established through Delegated Decree No. 116 of 10 August 2026. The Decree allows qualifying taxpayers to enter into unilateral, bilateral, or multilateral advance rulings/agreements regarding:

• The determination of the normal market (arm's length) value of transactions with related cross-border entities;
• The determination of the value of assets when relocat…