Tax Treaties in South Sudan
South Sudan has a very limited tax treaty network. As a young nation (independence in 2011), it has not yet developed an extensive network of double tax treaties (DTTs) with other countries.
Tax Treaty Network
South Sudan has very few double tax treaties in force. The country is not a member of the OECD or the Inclusive Framework on BEPS. Taxpayers should seek professional advice on treaty availability for specific jurisdictions.
Withholding Tax Rates (Domestic)
Where no treaty applies, South Sudan's domestic withholding tax rates are:
| Income Type | Domestic Rate |
|---|---|
| Dividends | 10% |
| Interest | 10% |
| Royalties | 15% |
| Service Fees | 10-15% |
Transfer Pricing
South Sudan has limited transfer pricing rules. Related-party transactions should be conducted at arm's length, but formal documentation requirements are not yet fully developed.
Foreign Tax Credit
Resident taxpayers may claim a foreign tax credit for taxes paid abroad on foreign-source income, subject to limitations under domestic law.
Inbound Investment
Foreign investors in South Sudan are subject to:
- CIT on South Sudan-source income at 25% (30% for oil/petroleum)
- Withholding taxes on dividends, interest, and royalties
- Foreign investment approval may be required for certain sectors
Exchange of Information
South Sudan has limited participation in international tax information exchange. The country is not currently a signatory to the Multilateral Competent Authority Agreement (MCAA).