Comoros Tax Residency Guide: 183-Day Rule, DTTs 2026
Comoros determines tax residency based primarily on the 183-day physical presence test. Individuals present in Comoros for 183 days or more in a calendar year are considered tax residents and taxed on worldwide income. Comoros has a limited Double Taxation Treaty network, with treaties primarily with France and select francophone African countries. Here is how tax residency works in 2026.
Tax residency in Comoros is governed by the General Tax Code and determines an individual's or company's obligation to pay tax on worldwide versus Comoros-source income. The rules are aligned with francophone African tax standards. The Direction Générale des Impôts (DGI) is responsible for determining residency status and issuing Certificates of Residency for treaty purposes. Personal income tax →
Real-world example: A French expatriate spends 200 days in Comoros and 165 days in France. Since they exceed the 183-day threshold in Comoros, they become a Comorian tax resident and are taxable on worldwide income in Comoros. Their home country may also consider them resident — the applicable DTT (France-Comoros) is used to resolve dual residency via tie-breaker rules (permanent home, center of vital interests, habitual abode, nationality). Filing requirements for residents →
Individual Tax Residency Criteria
- 183-day rule: An individual is resident if present in Comoros for 183 days or more in any 12-month period (or calendar year)
- Permanent home: If an individual has a permanent home available in Comoros and spends more than 183 days abroad, they may still be resident if their center of vital interests is in Comoros
- Habitual abode: If no clear permanent home, the habitual abode test applies
- Nationality: Comorian nationals working abroad for the government may be presumed resident
Comorian tax residents are taxed on worldwide income. Non-residents are taxed only on Comorian-source income. The tax year is the calendar year.
Corporate Tax Residency
- Place of incorporation: A company is resident in Comoros if it is incorporated under Comorian law
- Place of effective management: A company is also resident if its place of effective management is in Comoros, even if incorporated elsewhere
- Permanent establishment: Non-resident companies with a PE in Comoros are taxed on PE-attributable income
Corporate residency determines whether a company is taxed on worldwide income (resident) or only Comorian-source income (non-resident with PE).
Double Taxation Treaties
Comoros has a limited Double Taxation Treaty network. Key treaty partners include:
- France: Comprehensive DTT covering dividends, interest, royalties, and capital gains — rates reduced to 5-15% depending on the income type
- Francophone Africa: Select treaties with other CFA franc zone countries (limited scope)
Treaties generally follow the OECD Model Convention and provide for reduced withholding tax rates. Comoros is actively working to expand its treaty network but remains a jurisdiction with limited treaty coverage compared to regional peers. For countries without a treaty, domestic withholding tax rates apply in full.
Certificate of Residency
A Certificate of Tax Residency can be obtained from the DGI to prove Comorian tax residency for treaty purposes. The certificate is typically issued for a specific tax year and states that the individual or company is a resident of Comoros for tax purposes. The application requires: tax identification number, proof of physical presence (for individuals), and confirmation of tax filings. Processing time is typically 10-20 business days.
Can I be resident in Comoros and another country?
Yes, dual residency is possible. The applicable DTT's tie-breaker clause determines which country has primary taxing rights. The tie-breaker tests are applied in order: permanent home, center of vital interests, habitual abode, and nationality. The country where you are not treaty-resident may still tax you on local-source income.
What happens if I spend less than 183 days in Comoros?
If you spend fewer than 183 days in Comoros and do not have a permanent home or center of vital interests in Comoros, you are generally a non-resident. You are taxed only on Comorian-source income. However, if you are a Comorian national, the authorities may presume residency unless you can demonstrate otherwise.