Tax Residency in Sao Tome and Principe

Determining tax residency is a critical first step in understanding your tax obligations in Sao Tome and Principe. This guide explains the rules for both individual and corporate tax residency, and the consequences of each status.

Individual Tax Residency

Resident Criteria

An individual is considered a tax resident of Sao Tome and Principe if they meet any of the following conditions:

• 183-Day Test: Present in Sao Tome and Principe for 183 days or more in a calendar year
• Permanent Home: Has a permanent home available in Sao Tome and Principe
• Center of Vital Interests: Personal and economic interests are primarily in Sao Tome and Principe
• Habitual Abode: Customarily resides in Sao Tome and Principe

Tax Obligations

• Residents: Taxed on worldwide income
• Non-Residents: Taxed only on Sao Tome and Principe-source income

Dual Residency

Where an individual qualifies as a resident of both Sao Tome and Principe and another country, tax treaties (where applicable) will provide tie-breaker rules to determine single residency.

Corporate Tax Residency

Resident Company Criteria

A company is considered a tax resident of Sao Tome and Principe if:

• Incorporated under local law, or
• Place of effective management is in Sao Tome and Principe

Tax Obligations

• Resident Companies: Taxed on worldwide income
• Non-Resident Companies: Taxed only on local-source income

Permanent Establishment (PE)

A non-resident enterprise is subject to corporate income tax in Sao Tome and Principe if it has a permanent establishment there. PE includes:

• A place of management
• A branch office
• A factory or workshop
• A construction site lasting more than 6 months
• An agent with authority to conclude contracts

Changing Residency

Individuals leaving Sao Tome and Principe should notify the tax authorities. Exit tax rules may apply to certain deemed disposals of assets. Companies redomiciling require approval and must settle all tax liabilities.