Corporate Income Tax in Sierra Leone

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

Who this applies to

Companies whose ordinary Sierra Leone income-tax position needs to be established from residence, income source and actual activity. The NRA-hosted 2017 consolidation says a company is resident if formed under Sierra Leone law, effectively managed and controlled there, or undertaking the majority of its operations there. A Sierra Leone permanent establishment of a non-resident person is treated as a separate resident person associated with its owner. Resident taxpayers' base is income from all sources less allowed deductions; non-resident taxpayers have the specific withholding-payment and other Sierra Leone-source limbs of s.16. Income Tax Act ss.12-16, NRA 2017 consolidation.

This is a source-bound draft, not a complete operative-2026 computation. The consolidation itself says it is unofficial. The enacted Finance Acts below supply specific later amendments, but complete reconciliation, prescribed returns, special regimes and the minimum-tax schedule question remain open. Finance Act2026 s.1 deems that Act operative from1January2026 unless otherwise provided. Finance Act2026 s.1. Independent review of this corporate rewrite is pending.

Rates, bands and thresholds

Component and conditions	Opened rule	Official source
Ordinary resident-company income-tax rate	Finance Act2026 replaces the First Schedule PartIII resident-company25% with30%; a distinct enacted special regime still needs separate eligibility checks	Finance Act2026 s.13(a)
MAT comparison	Replace s.7A(1): company income tax is the higher of the ordinary chargeable-income tax and the applicable First Schedule PartIII percentage of annual turnover; do not limit the trigger to current-year losses	Finance Act2026 s.5
MAT percentage wording	unverified as a universal rate: 2024 inserts2% for resident companies reporting losses in the previous year, while the earlier2023 insertion states3% more broadly. Resolve their application to this company before selecting a rate	Finance Act2024 s.11(a); Finance Act2023 s.6
MAT exceptions in the opened amendment	First3 assessment years after incorporation; first2 after entry into liquidation; existing investment agreements including bilateral tax agreements until expiry or review, whichever is earlier	Finance Act2025 s.8, replacing s.7A(4)
Carried-forward ordinary losses, baseline	Maximum10 years after the loss year; deduction at most50% of chargeable income computed before that loss deduction, subject to ownership-change rules	Income Tax Act s.32A; s.88, 2017 baseline
Financial-cost restriction	Financial gains plus30% of business income computed with the specific s.35(3) exclusions; not a flat30% of gross turnover. Disallowed costs carry forward in order incurred, maximum5 years	Finance Act2021 s.12, replacing s.35
MAT credits, opened2024 provisions	Credit equals MAT paid for the year; carry forward10 subsequent assessment years against income tax, not MAT; non-refundable and oldest first. Post2026 interaction still requires reconciliation	Finance Act2024 s.8, s.7A(2)-(3)

The ordinary30% rate does not by itself establish the final amount payable. The MAT percentage/exception, specialist regime, credits and payment history must be settled before filing. Do not carry forward the predecessor's approximate3% as an operative universal answer.

The base

1. Record incorporation, management/control, location of the majority of operations, permanent-establishment facts, year end and business category. Build the residence/source conclusion before choosing a rate. Shipping/insurance/extractive operations and investment agreements need their own regime workpaper. Income Tax Act ss.12-20, 2017 baseline.
2. Bridge accounts to assessable business/property income and permitted deductions. Section24 includes gains on disposal of business assets other than depreciable assets and gains on satisfaction of business debts, whether capital or revenue, plus business-related gifts, restrictive-business payments, trade-receivable/banking interest, business property letting and insured trading stock. Section32(1)(a) allows expenses to the extent incurred in producing assessable income. Personal expenses, income tax and government fines do not become deductions merely because recorded in the accounts; other categories have specific statutory restrictions. Income Tax Act ss.24-25,32, 2017 baseline.
3. Add back accounting depreciation and compute verified capital allowances from the actual asset pool, use, in-service dates and disposal proceeds. Section39 has separate pools, a balancing inclusion when disposal proceeds exceed the pool, mixed-use apportionment and a different extractive schedule. Do not assume a percentage without reconciling the relevant current schedule. The former s.40 investment allowance is expressly repealed by Finance Act2026, as is Ninth Schedule paragraph6. Income Tax Act s.39, 2017 baseline; Finance Act2026 ss.7,15(b).
4. Maintain losses by origin year and type. Apply s.32A's baseline expiry and50% cap before computing the ordinary component. A50% or greater underlying ownership/control change brings s.88's same-business/no-new-business-or-investment-without-approval conditions for3years into the check. The printed s.88 cross-reference is stale relative to s.32A; do not silently repair it into an independently certified current rule. Group relief needs separate reconciliation of the2021 insertion and current conditions. Income Tax Act ss.32A,88, 2017 baseline; Finance Act2021 s.11.
5. Compute financial costs under the replaced s.35. Its business-income measure excludes specified financial gains, asset/debt gains and pool-balancing amounts, and does not deduct financial costs, capital allowances or the specified losses. Track denied costs separately from ordinary carried-forward losses. Current subsidiary instruments and interaction with special regimes are not cleared. Finance Act2021 s.12.
6. Compute ordinary income tax, then perform a separate MAT workpaper using the verified applicable schedule rate and exception. The opened s.7A(5) excludes final-withholding amounts from turnover and, for a non-resident company, foreign-source amounts unless effectively connected with its Sierra Leone PE. Keep MAT credits separately from ordinary losses and withheld-tax credits. Finance Act2024 s.8; Finance Act2025 s.8; Finance Act2026 s.5.

The2021 amendment separately provides15% for manufacturing entities/factories whose management and functional activities are exclusively outside the Western Area, subject to s.3. This is a specific source provision to reconcile, not permission to apply a generic agriculture/priority-sector holiday or the standard rate to every company. Eligibility, later changes and MAT interaction remain unapproved. Finance Act2021 s.8, inserting s.5(c).

Deadlines and filing

The2017 baseline s.97 requires the annual return and arrangements to pay its balance within four months after the assessment year, not a universal120-day substitute. For a calendar year that points to30April, subject to any evidenced current extension or different notice. Section97(2) allows a written requirement for a shortened activity period. Finance Act2026 replaces s.97(3): return format, information and filing, including TP returns, are prescribed by the Commissioner-General and published in the Gazette. The actual current format/portal fields and payment-acceptance evidence have not been authenticated. Income Tax Act s.97(1)-(3), baseline; Finance Act2026 s.8.

Baseline s.113 estimates chargeable business income/turnover by31January, with review opportunities by30April and31October. For a substituted assessment year, make the initial estimate by the end of its first month; the first review opportunity is by the end of its fourth month; the second follows the literal statutory wording “on or before the tenth month” of that substituted year. Calendar-year instalments fall15March,15June,15September and15December; substituted years use the15th day of months3,6,9,12. Cumulative percentages are25%,50%,75%,100% of estimated tax, less preceding instalments; the balance falls due with the annual return. Withheld-tax reduction requires the Commissioner's approval under s.113(7). These are opened baseline rules, not proof that the full later calendar and MAT instalment method have been reconciled. Income Tax Act s.113, 2017 baseline.

Collect TIN/registration, signed return, accounts and relevant branch breakdown, tax bridge, asset/loss/MAT/withholding registers and the actual prescribed attachments. Baseline s.97(6)-(8) distinguishes accounts requirements by taxpayer category. Related-party transactions also require the separate transfer-pricing Guide; do not treat its submission clocks as the ordinary company return deadline. The2026 Act sets the tax-clearance fee at NLe100 for all categories under the opened2026 amendment; the fee alone does not establish clearance entitlement or replace a return. Income Tax Act s.97(6)-(8), baseline; Finance Act2026 ss.8,15(c).

Penalties and interest

Finance Act2025 replaces s.97A: an income-tax return filed within30days after its due date is a late filing; one filed after30days is a non-filing for that classification. It replaces s.150 with the following annual-return penalties, preserving the statutory good-cause qualification for a late filer. Do not use the lower monthly-return amounts for an annual company return. Finance Act2025 ss.9-10.

Annual-return category	Late filer without good cause	Non-filer	Official source
Large	NLe25,000	NLe50,000	Finance Act2025 s.10, s.150(1)(a)-(b)
Medium	NLe12,500	NLe25,000	Finance Act2025 s.10, s.150(1)(a)-(b)
Small	NLe1,250	NLe2,500	Finance Act2025 s.10, s.150(1)(a)-(b)

Finance Act2025 s.7 defines large by annual turnover above NLe6million and other additional requirements prescribed by the Commissioner-General; medium is above NLe500,000 up to NLe6million; small is above NLe10,000 up to NLe500,000; micro is NLe10,000 or below. Verify actual classification/additional requirements. The penalty table has no micro-company amount to invent. Under s.150(2), an incorrect chargeable-income return without good cause attracts25% of the resulting tax difference, not25% of revenue. Late-payment interest, instalment underestimation and interactions with the Revenue Administration Act need their separate current legal chain; no live money-interest figure is approved here. Finance Act2025 ss.7,10.

Cross-border points

Preserve resident versus non-resident schedules. The opened2024 resident-payment table has contractor5%, dividend15%, interest15%, management/professional15% and royalty15%; Finance Act2026 changes its rent10% to15%. The2026 non-resident-schedule changes raise contractor10% to20% and dividend, interest and management/professional15% to20%. Those amendments do not say every non-resident payment is20%, or change the royalty rate in that clause. Payment scope, thresholds, final versus credit treatment, treaty entitlement, gross-up and remittance remain to be reconciled before applying a withholding rate. The old6.5%/11.5% contractor rates, blanket resident/non-resident15% claims and NLe500 threshold are not adopted. Finance Act2024 s.11(b); Finance Act2026 ss.13(b),14.

Residence/PE, treaty priority and anti-avoidance must be checked together. Related-party pricing and deductibility require the separate TP workpaper, not an assumption that paying withholding tax makes the expense deductible. Foreign-tax-credit method, treaty-by-treaty reductions and the old standalone non-resident30% claim are held pending full governing-text reconciliation.

Two worked examples that recompute

First assume an ordinary resident company, verified current ordinary rate30%, adjusted assessable income NLe1,000,000 and allowed expenses/capital allowances NLe400,000. Ordinary chargeable income is NLe600,000 and its profit-tax component is NLe180,000. This is not final cash tax: MAT, special regimes, credits and prior payments are deliberately not assumed resolved.

name: Ordinary resident-company profit-tax component only
inputs:
  assessable_income: 1000000
  allowed_deductions: 400000
steps:
  - chargeable_income: assessable_income-allowed_deductions
  - ordinary_tax: chargeable_income*0.30
expected:
  chargeable_income: 600000
  ordinary_tax: 180000

Next assume the opened s.32A conditions are verified applicable, there is no disqualifying ownership change, income before carried losses is NLe1,000,000 and unexpired available losses are NLe800,000. The50% limit permits NLe500,000, leaving NLe300,000 unused loss and ordinary tax NLe150,000. Deducting all NLe800,000 instead gives only NLe60,000, understating that ordinary component by NLe90,000. Choose the capped workpaper, not the unrestricted deduction. This conditional example proves neither the whole current loss chain nor the separate MAT outcome.

name: Capped versus unsupported full loss utilisation
inputs:
  income_before_carried_losses: 1000000
  available_unexpired_losses: 800000
steps:
  - allowed_loss: min(available_unexpired_losses,income_before_carried_losses*0.50)
  - remaining_loss: available_unexpired_losses-allowed_loss
  - correct_ordinary_tax: (income_before_carried_losses-allowed_loss)*0.30
  - unsupported_full_loss_tax: (income_before_carried_losses-available_unexpired_losses)*0.30
  - understatement: correct_ordinary_tax-unsupported_full_loss_tax
expected:
  allowed_loss: 500000
  remaining_loss: 300000
  correct_ordinary_tax: 150000
  unsupported_full_loss_tax: 60000
  understatement: 90000

Ask the client first

Obtain residence/management/PE and business-sector facts; incorporation/liquidation dates and agreements; year end and prior-year profit/loss; reconciled accounts, assets, loss-age/ownership and finance-cost records; distributions and cross-border/related-party payments; and actual TIN, returns, category, instalments, withholding certificates, assessment notices and payment evidence.

Sources

Primary source and actual read scope	Official URL	Read on
NRA-hosted unofficial Income Tax Act consolidation through Finance Act2017. Read ss.12-16; ss.24-25,32-32A;39;88;97;113 and relevant neighbours. No claim the entire145-page file is current law.	https://webtestcms.nra.gov.sl/uploads/Income_Tax_Act_2000_as_amended_to_Finance_Act_2017_1_83760e046c.pdf	2026-11-01
Enacted Finance Act2021: ss.8,11-12 and neighbouring definitions/related provisions, printed8-11, physical5-6.	https://webtestcms.nra.gov.sl/uploads/Finance_Act_2021_be1efb0bcc.pdf	2026-11-01
Enacted Finance Act2023: ss.5-6, original MAT structure and3% insertion.	https://webtestcms.nra.gov.sl/uploads/The_Finance_Act_2023_8629ff7803.pdf	2026-11-01
Enacted Finance Act2024: ss.8-12, replacement MAT, digital source neighbour, annual-return compatibility and resident withholding table, printed14-18, physical8-10.	https://webtestcms.nra.gov.sl/uploads/The_Finance_Act_2024_0d6d83e684.pdf	2026-11-01
Enacted Finance Act2025: ss.7-10, classification, MAT exceptions and annual/monthly penalty distinctions, printed7-9, physical7-9.	https://webtestcms.nra.gov.sl/uploads/The_Finance_Act_2025_beb680faed.pdf	2026-11-01
Enacted Finance Act2026: commencement and income-tax ss.4-15, printed5-9 and relevant neighbours; actual PDF physical5-9 half-pages read in order.	https://webtestcms.nra.gov.sl/uploads/The_Finance_Act_2026_121df05d9b.pdf	2026-11-01

Not yet confirmed: Complete operative2026 amendment/commencement and subsidiary-instrument chain, authoritative current consolidation, application of the2023/2024 MAT schedule percentages to all company cohorts and current MAT-credit/instalment implementation; current special manufacturing/agriculture/priority/mining/petroleum/shipping/insurance/investment agreement regimes; non-resident company rate and foreign-tax/treaty relief; current loss/ownership/group-relief interaction and financial-cost instruments; capital-allowance rates; withholding scope/thresholds/finality/treaty/gross-up/payment forms; full current filing/payment/extension calendar, certified-account requirements by current class and gazetted/ITAS return fields; Revenue Administration Act interactions, late-payment interest/underestimation and current appeal/recovery path. The predecessor's approximate3% MAT, universal120days, agriculture holidays, mining30%, universal non-resident30%, resident/non-resident15% withholding,6.5%/11.5% contractor rates and NLe500 threshold are expressly held or corrected above, never silently retained. Independent corporate source review pending; IT-CORP and related domains remain partial.