Part II · Jurisdictions · No. 09

San Marino

A small landlocked European microstate whose aircraft registry — T7-prefix — has emerged as an alternative to Isle of Man for private aircraft operating in the European Economic Area. The register is kept by the state regulator, now the Civil Aviation Maritime Navigation and Homologation Authority (CAA-MNA), and is marketed internationally with private-sector partners.

Why this jurisdiction matters

San Marino is not an EU member. Its aircraft registry (T7 nationality mark), launched in December 2012, provides an alternative European registration for private and corporate aircraft and is also open to commercial air transport. It has grown materially since then, particularly for aircraft owned by non-EU residents who operate principally in European airspace.

The relevant tax regime

• General income tax (IGR): 17% for companies; individuals progressive from 9% to 35% (top rate above €80,000); capital gains taxed in certain circumstances.
• No specific aircraft-ownership tax for non-resident owners.
• San Marino is in a customs union with the EU but outside the EU VAT area. It has no VAT and instead levies a single-stage import tax (imposta monofase), so the VAT analysis of an aircraft purchase or import is separate from EU intra-Union rules. The registry states that registered fixed-wing aircraft above 5,700 kg MTOW, and turbine helicopters, are exempt from San Marino import taxes and duties. EU import VAT still applies to aircraft brought into free circulation in the EU.

Registration or residency mechanics

Aircraft registration is made with the CAA-MNA, usually through local representatives. The owner does not need to be a San Marino resident. Safety oversight follows ICAO standards, with national regulations modelled on EASA requirements. San Marino is not an EASA member state, so T7 aircraft operating commercially in the EU need the appropriate third-country authorisations.

Reporting and disclosure

CRS participant. FATCA Model 2 IGA with the U.S. (in force 30 August 2016). Beneficial-ownership registration applies to San Marino-formed entities. Aircraft registration records the owner and operator.

The substance question

San Marino registration is an alternative to Isle of Man for owners not seeking the specific VAT-import structures historically used through IOM. Substance for the owning entity follows the home-jurisdiction substance rules of the actual operator.

Recent changes

The registry has grown steadily. The EU–Andorra–San Marino association agreement (negotiations concluded December 2023) was cleared by the EU Council for signature and provisional application on 16 July 2026. It deepens San Marino’s alignment with EU internal-market rules, and its implications for indirect tax should be monitored. Status as of October 2026.

Common asset classes parked here

• Private aircraft — particularly for owners operating in EU airspace under non-EU registration.

Reviewed October 2026