Sudan Tax Residency Guide — الإقامة الضريبية في السودان

Sudan tax residency rules for individuals and companies for 2026. The guide covers: the 183-day physical presence test — presence of 183 days or more in the calendar year triggers unlimited tax liability; the permanent home test — maintaining a permanent home in Sudan may establish residency; the double tax treaty tie-breaker — the hierarchy of tests for dual residents; and the exit rules — no formal exit tax, but continued obligations after departure.

183-Day Rule — قاعدة 183 يومًا

  • Physical presence test: An individual physically present in Sudan for 183 days or more in a taxable year (calendar year from January 1 to December 31) is classified as a Sudanese tax resident. Days of arrival and departure each count as a full day.
  • Calculation of days: Days are counted on an aggregate basis — all days spent in Sudan during the calendar year are summed, regardless of whether stays are consecutive or intermittent.
  • Permanent home test: Even if the 183-day threshold is NOT met, an individual may be considered tax resident if they maintain a permanent home in Sudan and are present for any period in the year.

Corporate Residency

  • Incorporation test: A company is considered a tax resident in Sudan if it is incorporated under Sudanese law.
  • Place of effective management: A company is also resident if its place of effective management is in Sudan, regardless of where it is incorporated.
  • Worldwide income: Resident companies are taxed on worldwide income at the standard corporate rate of 30%.

Double Tax Treaty Tie-Breaker

  • Tie-breaker hierarchy (OECD Model): When an individual is a dual resident, the DTA tie-breaker rules apply in the following hierarchy: (a) permanent home, (b) centre of vital interests, (c) habitual abode, (d) nationality.
  • Corporate tie-breaker: For companies, dual residency is resolved by the place of effective management (POEM) test under DTAs.
  • Mutual Agreement Procedure (MAP): If tie-breaker tests fail, the competent authorities of both countries may resolve the dispute through MAP.

Exit Rules — قواعد الخروج من الإقامة الضريبية

  • No formal exit tax: Sudan does NOT impose a formal exit tax on individuals leaving the country. There is no deemed-disposition charge on assets held at departure.
  • Continued obligations: Individuals who cease to be tax resident continue to be subject to Sudanese tax on certain types of Sudanese-source income (employment income for work performed in Sudan, rental income from Sudanese real estate).
  • Notification requirement: Departing residents should notify the Sudan Tax Authority of the change in residency status with evidence of new tax residency abroad.