Corporate Income Tax in Eswatini

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 with income from a source within or deemed within Eswatini, branches of non-resident companies, and payers of withholding tax. Tax year: the year of assessment 1 July 2025 to 30 June 2026. The latest amending law found is the Income Tax (Amendment) Act 2023. ERS says those amendments took effect on 1 July 2024. No 2026 amending law was found on the ERS site, and that absence is not proof that none exists.

Rates, bands and thresholds

Item	Amount and conditions	Tax year	Official URL
Company rate	25%. The ERS rates page still says 27.5%; the Third Schedule and the 2025 ERS notice say 25%	2026	https://www.ers.org.sz/whatsnew-file/1753959572719-FULL_PAGE___Income_Tax_Returns_Notice_2025.pdf
Presumptive tax, company turnover to E50,000	0%. Excludes professionals and investment income	2026	https://www.ers.org.sz/IncomeTax/PresumptiveTax
Presumptive tax, turnover above E50,000 and below E500,000	1.75% of total turnover	2026	https://www.ers.org.sz/IncomeTax/PresumptiveTax
Development enterprise, new business in a qualifying project	10% company rate for 10 years, not renewable, by agreement with the Minister and Cabinet approval. Sectors: manufacturing of an industrial, scientific or educational nature, mining or beneficiation, energy and power generation, assembly or agro-industry, tourism (s 69(2), Seventh Schedule)	2026	https://www.ers.org.sz/documents/IncomeTaxAmendmentAct2023.pdf
Interest deduction cap	Net interest above 30% of tax EBITDA denied, for group companies other than banks and insurers. Carry forward 3 years (s 65sep)	2026	https://www.ers.org.sz/documents/IncomeTaxAmendmentAct2023.pdf
Non-resident shareholders tax	15%; 12.5% for a company registered in Botswana, Lesotho, Namibia or South Africa that is not a subsidiary or branch of a company from elsewhere (s 21)	2026	https://www.ers.org.sz/documents/IncomeTaxOrder1975.pdf
South Africa treaty dividends	10% for a company holding at least 25%; otherwise 15% (art. 10)	2026	https://www.ers.org.sz/documents/SouthAfrica.pdf
Non-resident interest	10% . The ERS rates page shows 15% for outside SACU; ERS Withholding page and the Order say 10%	2026	https://www.ers.org.sz/IncomeTax/Withholding
Royalties and management fees to non-residents	15% of gross, final	2026	https://www.ers.org.sz/IncomeTax/Withholding
Non-resident contractors, construction	15%, excluding direct cost of materials	2026	https://www.ers.org.sz/IncomeTax/Withholding
Non-resident service payments	15% of gross on Eswatini-source service contracts	2026	https://www.ers.org.sz/IncomeTax/Withholding
Entertainers and sportspersons	15% of gross	2026	https://www.ers.org.sz/IncomeTax/Withholding
Branch profits tax	15%; 12.5% for a qualifying neighbouring-country company (s 32E)	2026	https://www.ers.org.sz/documents/IncomeTaxOrder1975.pdf
Resident interest and dividends paid	10%	2026	https://www.ers.org.sz/IncomeTax/Withholding
Rent paid to a non-company lessor by a non-natural person	10%	2026	https://www.ers.org.sz/IncomeTax/Withholding
Trust distributions to vested beneficiaries	33%	2026	https://www.ers.org.sz/IncomeTax/Withholding

The base

Source basis, regardless of residence. The 2023 Act added Division X (gains on business assets; the cost base is value at commencement for older assets), a permanent establishment definition and arm's length rules (ss 65quat onward). Controlled transactions use an approved transfer pricing method and need documents under s 35bis. The domestic exemption threshold is set by Gazette notice.

Deadlines and filing

For the year ended 30 June 2025 all non-individual entities filed and paid by 31 October 2025. Approved other year-ends: within 4 months after year-end. Draft financial statements were accepted, with signed audited ones to follow. Withholding is due by the 15th of the following month.

Provisional tax: first payment within 6 months of the start of the year, second by year-end, third by the return date. Presumptive taxpayers: 25%, 50%, 75% and 100% cumulative by 30 September, 31 December, 31 March and 30 June.

How to file

1. Appoint a Public Officer: board resolution, signed acceptance, certified ID, and work permit for a non-citizen.
2. Log in to TaxEase at https://taxease.ers.org.sz/ and complete the return. Attach the financial statements.
3. Dormant registered companies also file, and tell the Commissioner General in writing why they are not operating.
4. Pay by EFT, speed point, MoMo Pay or bank deposit, quoting the reference. Cash is not accepted.

Penalties and interest

Late return: 20% of tax payable (ERS). The daily penalty for default is E25 under s 40(8) as replaced in 2023; the ERS page still shows E20 a day on a loss, and the Act wins. Late payment: 18% a year. Failure to withhold: payer is liable plus 20%. Withheld but not remitted: 10% under 30 days late, 15% from 30 days, 20% from 90 days, 25% from 180 days. Under-estimating provisional tax below 90% of actual: 20% of the shortfall as defined. Records: 5 years.

Cross-border points

A foreign service paid by a business usually triggers 15% withholding and may also trigger VAT reverse charge. A treaty rate needs the treaty text read for that country.

Two worked examples that recompute

Company profit E800,000 at 25%.

name: Company tax on E800,000
inputs:
  profit: 800000
steps:
  - tax: profit * 0.25
expected:
  tax: 200000

Decision: a retail company with turnover E400,000 and profit E40,000 pays E7,000 presumptive against E10,000 normal. If profit were under E28,000, normal tax would be lower, and the company must weigh leaving presumptive tax, which it can do only after two years.

name: Presumptive or normal, company turnover E400,000
inputs:
  turnover: 400000
  profit: 40000
steps:
  - presumptive: turnover * 0.0175
  - normal: profit * 0.25
  - breakeven: presumptive / 0.25
expected:
  presumptive: 7000
  normal: 10000
  breakeven: 28000

Ask the client first

1. What is the year-end, and is it approved?
2. What is turnover, and is the business professional or does it have investment income?
3. Is it in a group, with related-party transactions or interest?
4. Who are the non-resident payees, and where are they resident?
5. Is it a branch of a foreign company?

Sources

Source	URL	Read on
ERS, Public Notice, returns for tax year end 2025 (scanned, OCR); cited sections read	https://www.ers.org.sz/whatsnew-file/1753959572719-FULL_PAGE___Income_Tax_Returns_Notice_2025.pdf	2026-11-01
Income Tax (Amendment) Act 2023 (Act 20 of 2023); scanned, read by OCR, Third Schedule pages checked by eye; cited sections read	https://www.ers.org.sz/documents/IncomeTaxAmendmentAct2023.pdf	2026-11-01
ERS, Rates and Thresholds; whole page read	https://www.ers.org.sz/IncomeTax/RatesandThres	2026-11-01
ERS, Withholding Taxes; whole page read	https://www.ers.org.sz/IncomeTax/Withholding	2026-11-01
ERS, Presumptive Tax; whole page read	https://www.ers.org.sz/IncomeTax/PresumptiveTax	2026-11-01
Income Tax Order 1975, ERS consolidated copy to the 2013 amendments; sections cited were read; cited sections read	https://www.ers.org.sz/documents/IncomeTaxOrder1975.pdf	2026-11-01
Eswatini and South Africa tax treaty, art. 10; cited sections read	https://www.ers.org.sz/documents/SouthAfrica.pdf	2026-11-01
ERS, Self Assessment; whole page read	https://www.ers.org.sz/IncomeTax/SelfAssessment	2026-11-01
ERS, Step-by-Step Guide for New Businesses; whole page read	https://www.ers.org.sz/documents/Step-ByStepGuideforNewBusinesses.pdf	2026-11-01
ERS, Income Tax Returns; whole page read	https://www.ers.org.sz/IncomeTax/IncomeTaxReturn	2026-11-01

Not yet confirmed: The commencement notice for the 2023 Act was not opened; 1 July 2024 rests on the ERS Presumptive Tax page. The ERS notice for returns for the year ended 30 June 2026 was not found, so 2025 dates are given as the latest published. The old pack's 5% royalty refund under a treaty and the four-year audit practice: no official source found. The old 120-day rule appears in the ERS guide, but the 2025 notice gives 4 months and 31 October. The old pack's routine 60-day filing extension: no official source found. The transfer pricing threshold, regulations and the intangibles cap percentage were not found.