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Seychelles: Offshore Legal and Tax Regimes

Tax Treatment of Offshore Operations

See Domestic Corporate Taxation for the general principles of Seychelles corporate taxation, which also apply to offshore entities except as indicated below.

Offshore Seychelles entities are subject to the following fee and tax structures:

International Business Companies pay a registration fee of USD100.

The continuing annual renewal fee for IBC status is the same amount. There is a scale of fees in the International Business Companies Act covering inspection of documents in the Registry, copies of entries, increase of capital etc. etc. The fee levels are fixed for the life of an IBC, whatever subsequent changes may take place to fee levels.

IBCs are exempt from the Business Tax, from withholding taxes and from Stamp Duty; however they must pay tax on the non-monetary benefits of employees unless the IBC is in the International Trade Zone (see below) or the employees are crew members of a ship in international waters.

Offshore (Non-Domestic) Banks pay a license application processing fee of USD2,000 and an annual license fee of between SR250,000 and SR1m, depending on the value of total assets. See Offshore Business Sectors for details of the licensing regime. Banks are exempt from the Business Tax and withholding taxes, from customs duties and from Stamp Duty. They can if they wish elect to pay Business Tax at a rate which is agreed with the Commissioner of Taxes. Banks pay social security contributions in respect of their employees (see Personal Taxation).

Offshore (Non-Domestic) Insurance Companies pay license application processing fees and annual license fees as follows:

  • License application processing fee USD500 for an offshore license;
  • Annual license fee USD1,500 for either offshore general insurance or offshore life insurance;
  • Annual license fee USD3,000 for both offshore life and general business;
  • Annual license fee USD1,000 for a single-parent captive insurer.

See Offshore Business Sectors for details of the licensing regime.

Offshore insurance companies are exempt from the Business Tax, from withholding taxes, from customs duties and from Stamp Duty. They can if they wish elect to pay Business Tax at a rate which is agreed with the Commissioner of Taxes. There is a guarantee of exemption from future taxes for 20 years from the time of registration. Insurance companies pay social security contributions in respect of their employees (see Personal Taxation).

International Free Zone (SITZ) Companies pay annual license fees and application processing fees as follows:

  • Redistribution license: USD550;
  • Light Assembly License: USD550;
  • Manufacturing License: USD2,700 plus USD1,300 initial processing fee;
  • Processing License: USD2,700 plus USD1,300 initial processing fee;
  • Export Services License: USD1,500 plus USD500 initial processing fee.

These license fees are fixed for the life of a licensed company. See Law of Offshore for details of the regulatory regime and licensing process for SITZ companies.

SITZ companies are exempt from the Business Tax, from withholding taxes, from customs duties and from Stamp Duty.

International (Offshore) Trusts pay an initial registration fee of USD100. Offshore Trusts are exempt from the Business Tax, from withholding taxes and from Stamp Duty. See Law of Offshore for a details of Seychelles Trust legislation.

Limited Partnerships pay a registration fee of USD200. They may receive income from sources outside of Seychelles and distribute such income to foreign partners without incurring a Seychelles tax liability. In addition:

  • An LP is exempt from all Seychelles tax or duty on income or profits of the LP;
  • An LP is exempt from stamp duty on property transfers, share transfers and other business transactions;
  • An LP is exempt from trades tax on all furniture and equipment imported into Seychelles for office use;
  • An LP has exemptions under the Social Security Act.

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

Special Licence Companies (CSL) pay a US$D00 application fee, an annual licence fee of USD1,000, and a USD200 annual filing fee. They may carry on permitted business inside as well as outside of Seychelles. The CSL entity is a Seychelles domestic company (under the Companies Act 1972), which is granted a special licence under the Companies (Special Licence) Act and has access to Seychelles' steadily expanding network of double taxation avoidance treaties - of particular interest is its DTA with China. In addition:

  • A CSL is liable to Seychelles business tax at the rate of 1.5% on its world-wide income (as an exception to the Seychelles territorial tax system, any foreign income derived by a CSL will be deemed to be Seychelles-sourced income);
  • A CSL is exempt from withholding taxes on dividends, interest and royalties.
  • A CSL is exempt from stamp duty on property transfers, share transfers and other business transactions.
  • A CSL is exempt from trades tax on all furniture and equipment imported into Seychelles for office use.
  • A CSL has exemptions under the Social Security Act and from work permit fees for expatriate workers.

These exemptions granted under the CSL Act are guaranteed for ten years and continue in force thereafter unless otherwise provided for by written law.

 

 

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