Sudan Cross-Border Tax Guide — الضرائب العابرة للحدود

Sudan cross-border tax rules for 2026. The guide covers: the tax residency test — physical presence of 183 or more days triggering unlimited tax liability on worldwide income; the non-resident taxation — non-residents taxed only on Sudanese-source income; the treaty network — Sudan has DTAs with several countries; the foreign tax credit — unilateral relief available under domestic law; and special investment regimes under the Investment Encouragement Act 2021.

Tax Residency — الإقامة الضريبية

183-day physical presence test: An individual physically present in Sudan for 183 days or more in a taxable year is classified as a Sudanese tax resident. Days of arrival and departure count as full days.
Worldwide income for residents: Sudanese tax residents are subject to tax on their worldwide income at progressive PIT rates (0–15%) or the corporate rate (30%). Foreign-source income is included in the taxable base, with credit for foreign taxes paid.
Source-only for non-residents: Non-residents are taxed only on Sudanese-source income, including employment income for work performed in Sudan, business profits from a permanent establishment, and Sudanese-sourced dividends, interest, and royalties.
Corporate residency: A company is a tax resident in Sudan if incorporated under Sudanese law or if its place of effective management is in Sudan.

Double Tax Treaty Network — شبكة اتفاقيات منع الازدواج الضريبي

Treaty partners: Sudan has concluded double tax treaties with several countries, including Egypt, Saudi Arabia, the UAE, Qatar, Kuwait, Bahrain, Jordan, Syria, Yemen, Turkey, China, India, Pakistan, and the United Kingdom. The treaty network is concentrated in the Middle East, Africa, and Asia.
Treaty provisions: Sudan's DTAs generally follow the OECD Model Tax Convention with standard provisions on business profits (Article 7), dividends (Article 10), interest (Article 11), royalties (Article 12), and capital gains (Article 13).
Treaty relief procedure: To claim treaty benefits, taxpayers must obtain a certificate of tax residence from the residence country and submit it to the Sudan Tax Authority.

Foreign Tax Credit — الائتمان الضريبي الأجنبي

Unilateral foreign tax credit: Under Sudanese tax law, residents are entitled to a unilateral foreign tax credit for foreign taxes paid on foreign-source income included in the Sudanese taxable base. The credit is limited to the lower of actual foreign tax paid or the Sudanese tax attributable to the foreign-source income.
Treaty foreign tax credit: DTAs typically provide for the credit method to eliminate double taxation.
Claim procedure: To claim the foreign tax credit, taxpayers must submit evidence of foreign tax paid (foreign tax assessment or receipt).

Special Investment Regimes — الأنظمة الخاصة

Investment Encouragement Act 2021: The Investment Encouragement Act provides significant incentives for foreign and domestic investors, including: (a) reduced corporate tax rates of 10% for agricultural, industrial, and renewable energy projects, (b) 5–10 year tax holidays for strategic projects, (c) customs duty exemptions on imported machinery and equipment, (d) simplified licensing procedures through the Ministry of Investment.
Free zones: Sudan has established free zones where companies enjoy: exemption from corporate tax for profits generated within the free zone, exemption from customs duties and VAT on imported goods, and simplified customs procedures.
Special economic zones: Selected areas may qualify for special economic zone status with additional incentives, including reduced social insurance obligations for foreign workers.
Transfer pricing: Sudan has introduced transfer pricing rules requiring related-party transactions to be conducted at arm's length. Documentation requirements apply to transactions exceeding prescribed thresholds.