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, Vietnam , United Arab Emirates.

Some negotiations concluded and awaiting date for signature: Russia, Egypt.

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 in or 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

As of January 1, 2019, CSLs are taxed in accordance with the prevailing rates specified in the Professional Tax Act.

However, CSLs that received a special license on or before October 16, 2017 may still benefit from the 1.5% revoked preferential tax rates, unless they decide otherwise, until June 30, 2021.

(a) In the case of a business (special licenses), the tax is 1.5% on turnover or 25% on profits if the turnover is less than or equal to Rs 1 million Seychelles.

For companies whose turnover exceeds 1 million Seychelles Rupees, the tax is 30% on profits.

(b) A Company Special License in Seychelles is exempt from tax on assets or dividends, on royalties. It is also exempt from registration fees on transfers of ownership, shares or other financial transactions

The withholding tax rates on payments made by the Company (special license) are as follows:

(i) With respect to the dividend paid to a resident – 0%

(ii) Regarding the dividend paid to a non-resident – 0%

(iii) In respect of interest paid to a resident – 0%

(iv) In respect of interest paid to a non-resident – 0%

(v) With respect to royalties paid to a non-resident for use or right of use, any right of copy, patent, design, pattern or trademark – 0%

(vi) With respect to royalties paid to a non-resident for use or right of use, any secret formula, process or know-how, whether technical know-how, management or other, as well as any other right or intellectual property – 0%

(vii) With respect to royalties paid to a non-resident for the use or right to use any industrial, commercial or scientific equipment

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 .

“Société Internationale” 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, research an office, etc …