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 registry is operated by the Civil Aviation Authority of San Marino through a private operator.

Why this jurisdiction matters

San Marino is not an EU member. Its aircraft registry (T7-prefix) was established to provide an alternative European registration for private and corporate aircraft. The registry has grown materially since the early 2010s, particularly for aircraft owned by non-EU residents who operate principally in European airspace.

The relevant tax regime

• Corporate tax 17%; individual income tax progressive to 35%; capital-gains tax in certain circumstances.
• No specific aircraft-ownership tax for non-resident owners.
• San Marino is not in the EU VAT zone; VAT analysis on aircraft purchase is therefore separate from EU intra-Union rules.

Registration or residency mechanics

Aircraft registration through CAA-SM via approved operators (e.g., Registro Aeronautico San Marino). Owner does not need to be resident of San Marino. EASA-compliant safety oversight.

Reporting and disclosure

CRS participant. Beneficial-ownership registration applies to San Marino-formed entities. Aircraft registration discloses operator and owner.

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

Registry has grown steadily. San Marino has signed information-exchange agreements with major jurisdictions; transparency has progressed toward OECD standard.

Common asset classes parked here

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

Reviewed May 2026