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E-invoicing with San Marino

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published on 24 November 2021 | reading time approx. 2 minutes


Optional from 1 October 2021, mandatory from 1 July 2022. The Ministerial Decree of 21 June 2021, which came into force on 1 October 2021, established electronic invoicing also for the supply of goods between Italy and San Marino.
 
A transitional period is envisaged, from 1 October 2021 to 30 June 2022, during which invoices may be issued in both electronic and paper format; while from 1 July 2022 invoices may only be issued in electronic format, unless specific exclusions are provided for by law (for example taxable persons operating under the flat-rate scheme).

Electronic invoices for supplies of goods shipped or transported to the Republic of San Marino must:
  • be issued with document type “TD24”;
  • report the economic operator code (cd. COE) of the San Marino entity (consisting of 5 digits), preceded by the country code SM; 
  • indicate in the date field, the date of execution of the transaction that coincides with the date of commencement of transport or shipment from the territory of the State; in the recipient code field enter “2R4GTO8” and in the VAT field N3.3 (in the annual VAT return these transactions will be included in VE30 field 4);
  • contain the DDT data (number and date);

The SDI, after receiving the electronic invoice, sends it to the tax office of San Marino, which will validate it after verifying the regular payment of VAT on importation. The validated invoice will be available to the Italian transferor in his own area of the portal “invoices and receipts”, who will also be able to check the outcome of the control carried out by the tax office. 

If within 4 months from the issuance of the invoice the validated invoice is not received, within the following 30 days the Italian taxpayer must issue a variation note (with document type TD09) pursuant to article 26 of Presidential Decree number 633 of 1972 without penalties or interest, reporting in the field “related invoice data” the details of the invoice issued without VAT to the San Marino customer previously sent to the SDI which is the subject of the correction.

In case a paper invoice is issued, the Italian supplier, in order to invoice the goods to the San Marino taxable customer under a non-taxable regime, pursuant to article 8 of Presidential Decree 633/72, must issue 3 paper invoices and a single copy of the TD, 2 of which must be delivered to the San Marino transferee, who shall return to the Italian supplier a copy endorsed by the San Marino tax office.

Services rendered to San Marino operators may be documented by electronic invoice provided that the San Marino transferee communicates the identification code assigned by the Republic of San Marino.

In case of services out of the VAT field due to lack of territorial premise, the invoice can be sent in paper or electronic format; in the latter case the recipient code to be reported is “2R4GTO8” or “XXXXXXX”. If the invoice is sent with the addressee code of the Tax Office of San Marino, the latter will forward it to the taxpayer, but will not proceed to validate it as it is an option. If the invoice is sent with the addressee code “XXXXXXX”, the invoice is not sent to the Tax Office and a paper copy must be sent to the San Marino customer.

In the case of VAT-taxable services, as an alternative to the paper invoice, an electronic invoice can be issued, indicating only the recipient code “XXXXXXX”; consequently, as previously indicated, a paper copy must be sent to the San Marino client.

However, it is worth remembering that, as from 1 January 2022, the esterometer will be repealed, paper invoices from and to San Marino operators (private individuals or taxable persons) will have to pass through SDI, reporting as recipient code “XXXXXXX” or “2R4GTO8”.

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