RFND — Non-Domiciled Tax Residency (Residenza Fiscale Non Domiciliata – RFND)

The Non-Domiciled Tax Residency (Residenza Fiscale Non Domiciliata, or RFND) program was established by the Republic of San Marino as a strategic legislative instrument to bolster the nation’s luxury tourism sector and attract high-net-worth individuals to its unique microstate environment. Introduced through recent fiscal reforms aimed at diversifying the country’s economic profile, the RFND serves as a sophisticated bridge between traditional tourism and permanent residency. It was specifically designed to fill a critical gap in the immigration and tax landscape: providing a legal framework for affluent global citizens who wish to maintain a formal, recognized connection to San Marino without the long-term commitments or tax burdens associated with full residency. By creating this status, San Marino leverages its reputation for stability and exclusivity, offering a bespoke regulatory pathway that incentivizes frequent, high-value visitation while ensuring the country remains a competitive destination for the international elite who seek a secure, European-adjacent base for their seasonal lifestyle.

The ideal applicant for the RFND is a high-net-worth individual—such as a global entrepreneur, a retired executive, or a high-profile professional—who values privacy, security, and the prestige of San Marino’s hospitality infrastructure. The program is uniquely tailored to those who can afford to stay in accredited five-star hotel facilities for a duration of 30 to 150 days per year, effectively catering to individuals who prioritize luxury and convenience over the complexities of long-term relocation. Unlike traditional work visas or standard residency permits, which often require employment ties or permanent property ownership, the RFND is distinct because it is primarily a fiscal and lifestyle status that does not necessitate integration into the local labor market. The primary benefit is the acquisition of a formal, sanctioned status that grants the holder access to the country’s serene environment and high-end services, provided they have not been a tax resident in San Marino or a high-risk jurisdiction within the preceding seven years and possess a clean criminal record. While the program offers significant flexibility, it is limited by its strict requirement for residency within specific, government-accredited luxury accommodations, ensuring that the program remains an elite, niche offering that maintains the integrity and exclusivity of the Sammarinese brand.