Tax Treaties in Sao Tome and Principe
Cross-border taxation in Sao Tome and Principe covers how the country taxes foreign investments, income from abroad, and transactions between related parties. This guide provides an overview of the key rules and considerations for international investors.
Withholding Taxes
Sao Tome and Principe imposes withholding tax on payments to non-residents:
| Income Type | Domestic Rate |
|---|---|
| Dividends | 10% |
| Interest | 10% |
| Royalties | 15% |
| Service Fees | 15% |
| Rental Income | 15% |
Tax Treaties (DTTs)
Sao Tome and Principe has limited double tax treaty coverage. As of 2026, the country has signed a limited number of tax treaties, primarily with Portugal. Where treaties apply, they may reduce withholding tax rates and provide mechanisms for resolving double taxation disputes.
Transfer Pricing
Sao Tome and Principe follows the arm's length principle for related-party transactions. Transfer pricing documentation is required for:
- Transactions exceeding thresholds with related parties
- Intellectual property transactions
- Financing arrangements
Foreign Tax Credit
Resident taxpayers can claim a foreign tax credit for taxes paid abroad on foreign-source income. The credit is limited to the Sao Tome and Principe tax payable on that income.
Exchange of Information
Sao Tome and Principe participates in international tax cooperation. The country is not currently on any major tax haven blacklists but is working toward greater transparency.
Inbound Investment
Foreign investors in Sao Tome and Principe are subject to:
- IRC on local-source income at 25% (min 1% of gross turnover)
- Withholding taxes on distributions
- Foreign Investment Approval requirements for certain sectors
Outbound Investment
Sao Tome and Principe residents investing abroad are taxed on their worldwide income, with foreign tax credits available.