Taxation of Offshore Operations

Please consult the section titled Domestic Corporate Taxes for the general principles of Seychelles corporate taxation, which also apply to offshore entities unless indicated below.

The government levies taxes on offshore Seychelles entities based upon the following fee and tax structures.

International Business Companies (IBCs)

• Registration fees:

  • $100 for companies with authorized capital not exceeding $100,000

  • $1,000 for companies whose authorized capital is more than $100,000

• Annual renewal fees:

  • $100 for companies with authorized capital not exceeding $100,000

  • $1,000 for companies whose authorized capital is more than $100,000

• Other fees:

  • The International Business Companies Act provides a scale of fees that covers transactions such as document inspection in the Registry, entries copies, capital increases and so forth. The fee levels are fixed for the life of an IBC, regardless of any subsequent changes that may take place to fee levels.

  • IBCs are required to make social security contributions to the salaries of employees unless the IBS is located in the International Trade Zone or the employee is a crewmember of a ship in international waters.

• Exemptions:

  • the Business Tax

  • withholding taxes

  • the Stamp Duty

Offshore (Non-Domestic) Banks

• License application processing fee:

  • $2,000

• Annual license fee:

  • $2,000

• Other fees:

  • Offshore banks are required to make social security contributions to the salaries of employees.

• Exemptions:

  • the Business Tax*

  • withholding taxes

  • the Stamp Duty

  • customs duties

*Offshore banks are permitted to pay Business Tax at a rate that is agreed upon with the Commissioner of Taxes.

Offshore (Non-Domestic) Insurance Companies

• License application processing fee:

  • $500 for an offshore license

• Annual license fees:

  • $1,500 for either offshore general insurance or offshore life insurance

  • $3,000 for both offshore life and general business

  • $1,000 for a single-parent captive insurer

• Other fees:

  • Offshore banks are required to make social security contributions to the salaries of employees.

• Exemptions:

  • the Business Tax*

  • withholding taxes

  • the Stamp Duty

  • customs duties

  • At the time of registration, insurance companies also receive a guarantee of exemption from future taxes for a period of 20 years beginning at the time of registration

*Offshore banks are permitted to pay Business Tax at a rate that is agreed upon with the Commissioner of Taxes.

International Free Zone (SITZ) Companies

• Annual license fees and application processing fees*

  • Redistribution license: $550

  • Light Assembly License: $550

  • Manufacturing License: $2,700 plus a $1,300 initial processing fee

  • Processing License: $2,700 plus $1,300 initial processing fee

  • Export Services License: $1,500 plus $500 initial processing fee.

*Please note that these license fees are fixed for the life of a licensed company.

• Exemptions:

  • the Business Tax

  • withholding taxes

  • the Stamp Duty

  • customs duties

  • SITZ employers are exempt from making social security contributions to directors or employees.

International (Offshore) Trusts

• Registration fee

  • $100

• Exemptions:

  • the Business Tax

  • withholding taxes

  • the Stamp Duty

Limited Partnerships

• Registration fee

  • $200

• Exemptions*:

  • all Seychelles tax or duty on income or profits

  • stamp duty on property transfers, share transfers, and other business transactions

  • trades tax on all furniture and equipment that is important into Seychelles to be used in the office

  • miscellaneous exemptions under the Social Security Act

*These exemptions, which are granted under the LP Act, are guaranteed for twenty years and continue in force thereafter unless otherwise provided for by written law.

Please note that Limited Partnerships are permitted to receive income from sources outside of Seychelles and distribute such income to foreign partners without incurring a Seychelles tax liability.

Special License Companies (CSL)

• Various fees

  • application fee: $200

  • annual license fee: $1,000

  • annual filing fee: $200

• Business tax

  • 1.5% on its worldwide income, this is an exception to the Seychelles territorial tax system and does include foreign income

• Exemptions*

  • withholding taxes on dividends, interest, and royalties

  • stamp duty on property transfers, share transfers, and other business transactions

• trades tax on all furniture and equipment that is important into Seychelles to be used in the office

• miscellaneous exemptions under the Social Security Act

• work permit fees for expatriate workers

* The CSL Act guarantee the above mentioned exemptions for ten years and they will continue in force thereafter unless otherwise provided for by written law.

Please be aware that Special License Companies are permitted to conduct business inside as well as outside of Seychelles. According to the Companies Act 1972), the CSL entity is a Seychelles domestic company that is granted a special license under the Companies (Special License) Act and has access to Seychelles\' continuously growing network of double taxation avoidance treaties. Its double taxation avoidance treaty with China is particularly interesting to incoming investors