Eswatini

Cross Border in Eswatini

Eswatini cross-border income tax for the year of assessment 1 July 2025 to 30 June 2026 (tax year 2026) under the Income Tax Order 1975 as amended by the Income Tax (Amendment) Act 2023 (in force from 1 July 2024). Covers the source basis and the deemed-source rules, ordinary residence, the permanent establishment definition (fixed place, 30-day services test, dependent agents), non-resident shareholders tax at 15% (the 12.5% rate for Botswana, Lesotho, Namibia and South Africa companies is repealed), non-residents tax on interest at 15%, 15% final withholding on royalties and management charges, 15% on non-resident entertainers, contractors and service providers, branch profits tax at 15% (10% cap under the South Africa treaty protocol), the 10% minimum for non-resident individuals, exit taxation, the foreign tax credit on foreign interest, treaties, deadlines and penalties.