Friday, July 5, 2019
Brazil has announced that it has removed San Marino from its list of tax havens.
San Marino's removal from the black list will result in a lower withholding tax rate being charged – generally of 15 percent, down from 25 percent – on outbound payments, including capital gains, to businesses and entities in San Marino.
Entities in San Marino will also benefit from being absolved from enhanced transfer pricing scrutiny and more stringent rules concerning intra-group loan arrangements and the deductibility of expenses.
Its removal is because it generally levies a rate of corporate income tax of 17 percent. Although this rate falls below the 20 percent rate threshold typically required from territories for removal, Brazil said San Marino had demonstrated that it is fiscally transparent, in effectively sharing information on the tax affairs of domestic taxpayers.
The decision, included in Normative Instruction RFB no. 1.896 / 2019, was published in the June 28, 2019, edition of the Official Gazette.