SEYCHELLES Law and Practice Contributed by: Valery Freminot, Salina Sinon, Ruby Simeon and Hazel Naiken, Rivard Nariman
• Managerial fees paid to a non-resident by a financial institution operating in Seychelles are taxed at 33%. • Insurance premiums paid to a non-resident are taxed at 5%. • Interest on current accounts, fixed deposits and call deposits of residents and non-resi - dents (in Seychelles rupees or foreign cur - rency) are taxed at 5%. • Interest on savings accounts, bank-to-bank transfers and non-residents’ bank interest do not have withholding tax applied. • Managerial fees paid to a non-resident by a financial institution operating in Seychelles are taxed at 33%. • Interest on bearer bonds is taxed at 15%. • Interest paid by a person, being a non-finan - cial institution, to a person that is also not a financial institution is taxed at 15%. • Treasury bills (where the recipient is not a resident or a non-resident financial institution as defined in the Financial Institutions Act 2004 or carrying on the business of an insurer as regulated under Insurances Act, 2008)is taxed at 15%. • The rate of withholding from the gross pay - ment made to a specified business listed in the Fourth Schedule of the Business Tax Act is 15%. 5.2 Taxes Applicable to Businesses Pillar Two of the OECD Pillar Two of the OECD has not been implement - ed in Seychelles. Domestic Top-Up Tax This has not been introduced in Seychelles. 5.3 Available Tax Credits/Incentives Allowable Tax Deductions In Seychelles, various deductions are available for expenses such as:
• losses and outgoings; • repairs; • loss on property acquired for profit-making; • depreciation; • bad debts; • payments to shareholders; • directors; • associated persons and relatives; • subscriptions to associations; • contributions to the Seychelles Pension Scheme; and • gifts. Special Tax Rates For businesses involved in land cultivation, live - stock raising, or dairy production in Seychelles, special tax rates are applicable. Tax Depreciation The rates of depreciation allowable on capital investments (other than buildings) for farming and fisheries – as well as for tourism operators such as hotels, restaurants, transport, tour oper - ators, and travel agents – are as follows: • 30% in Year 1; • 25% in Year 2; • 20% in Year 3; • 15% in Year 4; and • 10% in Year 5. 5.4 Tax Consolidation There is no group taxation or tax consolidation in Seychelles. 5.5 Thin Capitalisation Rules and Other Limitations There are no thin capitalisation rules in Sey - chelles.
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