A tool for Tax Planning : OFFSHORE Company

Company Special License (CSL) in Seychelles’s Jurisdiction

To relocate his company in a country with no double taxation agreement can be a judicious chooses in tax planning.

Relocating a business in a non-double tax treaty country can be a sensible choice for investor tax planning.

Seychelles Special License Company (CSL) is a legal structure governed by the Seychelles Companies Act of 1972 supplemented by the provisions of the Companies Act of 2003.


This structure is more expensive than an offshore company IBC (International Business Company), but this company considered as a tax resident in the Seychelles offers the advantages of Double Taxation Avoidance Agreements (DTTA) signed by the Seychelles.

Double Taxation Avoidance Agreements

The Seychelles Islands has signed several double taxation treaties in particular with:
China , South Africa , Malaysia , Thailand , Indonesia  Mauritius, Oman, Zimbabwe, Botswana.

Some negotiations concluded and awaiting date for signature: Russia, Egypt, Vietnam , United Arab Emirates.

The jurisdiction of the Seychelles regularly signs Double Taxation Avoidance Agreements and our list is not kept up to date, you can consult directly following the link:


Company Special License or CSL : The Advantages

The Seychelles Company Special License (CSL) can do all legal activities outside Seychelles.

The Seychelles Company Special License (CSL) pay:

  • Initial application fees: USD 200
  • Annual License fees: USD 1,000
  • Annual filing fees: USD 200

During the life of the company, a Company Special License (CSL) is liable of a business tax at the rate of 1.5% on all its world-wide income.
Seychelles Company Special License (CSL) is exempt of withholding tax on dividend, interest and royalties of stamp duties  on property transfer, shares transfer and other business transactions.

A Seychelles Company Special License (CSL) is exempt de of trades tax on all furniture and equipment imported for the running of his office in Seychelles.

A Seychelles Company Special License (CSL) benefits of exemption of Social security contribution and fees for work permit for expatriate workers.

The objects of a Seychelles Company Special License (CSL) can be:

  • Investment management and advice
  • Offshore banking
  • Offshore insurance
  • Reinsurance
  • Business of:
    (a) an investment company
    (b) a holding company
    (c) a marketing company
    (d) a company holding intellectual property
    (e) a headquarters company
    (f) a human resources company
    (g) a franchise company
  • Business under a ITZ license
  • Any other business approved by the authority

The Articles of Association of a Company Special License (CSL) must be signed by at least two partners.

Two directors must be physical persons but not necessarily resident in the Seychelles, they must consent to their appointment, the secretary is the resident secretary (our company COTE D ‘AZUR-MAHE Registered Agent Ltd).

Our company, Cote d’Azur Mahe Registered Agent Ltd, secretary of your Company Special License (CSL), will can assist you in all the administrative procedures of creation and maintenance of your Company Special License (CSL) : establishing business plan, drafting of statutes in English, certification by notary, contact with a auditor, the Financial Services Authority, research an office, etc …