Seychelles

Cross Border in Seychelles

Seychelles cross-border business tax for tax year 2026 under the Business Tax Act 2009 (Cap 20) as amended. Covers residence of individuals (183 days, domicile, normal residence) and entities (incorporation, management and control), the permanent establishment test in section 2A (90-day construction and services tests, dependent agents, preparatory or auxiliary exclusions), Seychelles-source rules in section 5 including the foreign passive income and economic substance rule for members of multinational groups, the final withholding tax on dividends, interest, royalties, natural resource amounts, technical services fees and insurance premiums paid to non-residents, the 33% rate on managerial fees paid by financial institutions, the 3% tax on non-resident ships and aircraft, treaty precedence and the MLI principal purpose test.