As in neighbouring Italy, the San Marinese IPT legislation requires insurance companies to maintain an IPT Book detailing premiums collected in respect of risks located within the Republic’s boundaries. However, San Marino tax authorities have taken this requirement further and on 8 September 2015, a circular letter was sent to insurers and their fiscal representatives requesting the submission of IPT Books via an online portal with effect from 1 January 2016.
Given the sparse information included in the communication, FiscalReps has been in dialogue with the local Tax Office to seek clarification on this new requirement. It is our current understanding that the submission of the IPT Books is compulsory, starting with premiums collected on or after
1 January 2016. Failure to comply with this requirement will result in potential penalties ranging from €1,000 to €5,000.
Currently it appears that the 2014 (including December 2013) and 2015 IPT Books are not required to be submitted via the online portal.
With regard to authorised insurers, the fiscal representative is required to obtain logon credentials for the online portal and make the submission on behalf of the insurer. The IPT Book must be uploaded onto the portal on a quarterly basis by the end of the second month following the end of the relevant quarter. If no premiums are collected during the quarter, a nil report must be submitted. The first IPT Book to submit should therefore be the one related to the first quarter of 2016 due by 31 May 2016, with the corresponding IPT payment due by
30 April 2016.
The unauthorised insurer must submit the IPT Books directly. The tax office has requested that the logon credentials are obtained by the same person who signs the annual IPT return. The IPT book submission is due annually by the end of March following the relevant calendar year. If no premiums are collected during the year, a nil report must be submitted. Thus the first IPT Book should be the one related to calendar year 2016 and submitted by 31 March 2017, with the payment of the corresponding IPT due by the 28 February 2017.