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Seychelles Cross-Border Tax Guide: WHT 0-15%, DTTs, Transfer Pricing 2026

Seychelles' cross-border tax framework features zero withholding tax on dividends and interest paid to non-residents, royalties at 0-15%, a growing network of Double Taxation Treaties, and transfer pricing rules. Here is how cross-border taxation works in 2026.

Cross-border taxation in Seychelles is governed by domestic tax law and Seychelles' Double Taxation Treaties. The system is designed to facilitate international trade and investment while protecting Seychelles' tax base. Withholding tax rates on dividends and interest are 0%, making Seychelles a popular jurisdiction for holding company structures. Transfer pricing rules ensure that transactions between related parties are conducted at arm's length. The SRC has a dedicated international tax unit for cross-border matters. Investment income tax →

Real-world example: A UAE parent company receives SCR 1,000,000 in dividends from its Seychelles subsidiary. WHT = 0% (SCR 0). An Indian company licensing software to a Seychelles company receives SCR 500,000 in royalties: domestic WHT 0-15% depending on the type, potentially reduced under Seychelles-India DTT. A Mauritius company receiving interest of SCR 200,000 from a Seychelles borrower: WHT = 0%. The absence of exchange controls means funds can be repatriated freely. Corporate tax overview →

Withholding Tax Rates

  • Dividends to non-residents: 0% — no withholding on dividend payments
  • Interest to non-residents: 0% — no withholding on interest payments
  • Royalties to non-residents: 0-15% depending on type of royalty and treaty provisions
  • Management fees: May be subject to withholding if not at arm's length

The 0% WHT on dividends and interest is a significant advantage for international holding structures. Seychelles does not have exchange controls, so funds can move freely across borders.

Double Taxation Treaties

Seychelles has several DTTs covering major trading partners. Treaties generally provide for:

  • Dividends: 0% in many treaties, reflecting domestic law
  • Interest: 0% in many treaties, reflecting domestic law
  • Royalties: Reduced rates typically 5-10% (compared to 0-15% domestic)
  • Business profits: Only taxable in the source country if there is a permanent establishment
  • Capital gains: Generally taxable in the country of residence of the seller
  • Employment income: Taxable in the work country (subject to the 183-day exemption for short assignments)

Key treaty partners: South Africa, China, India, Mauritius, UAE, Qatar, Kuwait, Oman, Cyprus, Malta, Luxembourg, Belgium, Netherlands, UK, France, Sweden, Norway, Italy, Australia, Indonesia, Malaysia, Thailand, and others. Seychelles is actively expanding its treaty network.

Transfer Pricing

Seychelles' transfer pricing rules follow international standards. Key requirements include:

  • Arm's length principle: Transactions between related parties must be conducted as if between independent entities
  • Documentation: Taxpayers must maintain transfer pricing documentation
  • Methods: Acceptable methods include comparable uncontrolled price (CUP), cost plus, resale price, transactional net margin method (TNMM), and profit split
  • Penalties: Adjustments and penalties apply for non-compliance with arm's length principle

Related parties include parent-subsidiary relationships, sister companies under common control, and individuals with significant influence. The SRC may challenge transfer pricing arrangements that shift profits out of Seychelles.

Permanent Establishment Risk

Non-resident companies may create a taxable presence (permanent establishment) in Seychelles through: a fixed place of business (office, branch, workshop, construction site exceeding a threshold period), a dependent agent with authority to conclude contracts, or provision of services through employees for more than 183 days in any 12-month period. A PE is subject to CIT at 25% on profits attributable to the PE.

Can I repatriate profits from Seychelles tax-free?

Dividends paid to non-resident shareholders attract 0% WHT. Interest paid to non-residents also attracts 0% WHT. Royalties may attract 0-15% WHT (subject to treaty reduction). There is no branch remittance tax. Seychelles has no exchange controls, allowing free repatriation of funds.

What is the procedure for claiming DTT benefits?

The non-resident must provide the Seychelles payer with: a completed Treaty Relief Application form, a Certificate of Tax Residency from the home country tax authority, and a declaration of beneficial ownership. The payer then applies the treaty rate at source. Alternatively, tax can be withheld at the domestic rate and the non-resident can file a refund claim.