Seychelles IBC taxation

Seychelles International Business Company, by definition of the law, is not subject to any tax or duty on income or profits. Shareholders of Seychelles IBCs are also not subject to any tax on their income derived from the IBC. The corresponding provisions are included in Article 109.(1) of the Seychelles IBC Act, stated as follows:

109.(1) A company incorporated under this Act or a shareholder thereof shall not be subject to any tax or duty on income or profits accruing to or deriving from such company or in connection with any transaction to which that company or shareholder, as the case may be, is a party.

In the same way, Seychelles IBC is also exempt from any stamp duties on all transactions relating to its business, in particular on any transfers of property to or by the company, and on any transactions in respect of the shares, debt obligations or other securities of the IBC.

109.(2)
(a) all transfers of property to or by a company incorporated under this Act;

(b) all transactions in respect of the shares, debt obligations or other securities of a company incorporated under this Act; and

(c)  all other transactions relating to the business of a company incorporated under this Act,

are exempt from the payment of stamp duty.

Seychelles IBC is a completely zero-tax offshore company, insofar as it complies with a few simple rules of operation. All exemptions for a Seychelles offshore company shall remain in force for 20 years from the date of offshore company formation. In order to qualify as an offshore IBC, a Seychelles company must satisfy the following criteria as stated into Article 5.(1) of the Seychelles IBC Act:

5.(1)  For the purposes of this Act, an International Business Company is a company that does not -
(a) carry on business  in Seychelles;
(b) own an interest in immovable property situate in Seychelles, or a lease of immovable property situate in Seychelles otherwise than as referred to in subsection (2)(e);
(c) carry on banking as defined in the Financial Institutions Act, 1984 or a trust business;
(d) carry on business as an insurance or a reinsurance company; or
(e) carry on the business of providing the registered office for companies.

However, a Seychelles IBC may still engage into any of the following as stated into Article 5.(2) of the Seychelles IBC Act:

5.(2) For the purposes of subsection (1)(a), an International Business Company shall not be treated as carrying on business in Seychelles by reason only that -
(a) it makes or maintains deposits with a person carrying on business within Seychelles;
(b) it makes or maintains professional contact with counsel and attorneys, accountants, bookkeepers, trust companies, management companies, investment advisers or other similar persons carrying on business within Seychelles;
(c) it prepares or maintains books and records within Seychelles;

(d) it holds, within Seychelles, meetings of its directors or members;

(e) it holds a lease of property for use as an office from which to communicate with members or where books and records of the company are prepared or maintained;
(f) it holds shares, debt obligations or other securities in a company incorporated under this Act or under the Companies Act;
(g) it holds bonds, treasury bills and other securities issued by the Government of Seychelles or the Central  Bank of Seychelles;

(h) shares, debt obligations or other securities in the company are owned by any person resident in Seychelles or by any company incorporated under this Act or under the Companies Act; or

(i) it owns or manages a vessel registered in the Republic under the Merchant Shipping Act, or an aircraft, so registered under the Civil Aviation Act, 1949 (Overseas Territories) Order 1969.