Other Products

Portcullis TrustNet (Seychelles) Ltd is also able to assist clients with:

• Special Licence Companies for Access to Tax Treaties
• Protected cell companies for ring fencing liabilities
• Limited partnerships
• Free trade zone for manufacturing and professional services
• Mutual funds
• Offshore banking
• Offshore insurance
• Ship registration

The following are salient features of some of the above:

Special Licence Companies
These are domestic companies which have access to the expanding network of double tax treaties with Seychelles and are subject to corporate income tax of 1.5% only (see Companies (Special Licenses) Act, 2003.)

An obvious attraction of a CSL is that it enables a corporate enterprise which derives income from a high tax country which has a double tax treaty with Seychelles (see list below), to extract dividends, interest and royalties from the high tax country by positioning an intermediate holding company as the CSL in the Seychelles.

The main conditions for a CSL are as follows:

• Shareholders
  • At least 2 shareholders (need not be resident in Seychelles)
  • Corporate shareholders allowed
  • No bearer shares
  • Shareholder meetings may be anywhere
  • Nominee shareholder permitted, but name of beneficial owner recorded in register (under conditions of statutory secrecy)
  • Share capital any currency
• Directors
  • At least 2 directors (need not be resident in Seychelles, though this may be advisable for tax planning purposes to ensure control is in Seychelles)
  • Director's names publicly accessible
  • No corporate directors
  • Directors meetings anywhere
• Administrative
  • Seychelles resident secretary required
  • Annual return to be filed with SIBA
  • Annual accounts to be filed with SIBA
  • Audited accounts not required
  • Can be used for investment management and advice, investment company, holding company, marketing, holding intellectual property, headquarters company, human resources company, franchise company, business under ITZ licence, any other business approved by SIBA

The main benefits of a CSL are:
Can do business in Seychelles
Only tax is 1.5% on world-wide taxable income
No other taxes in Seychelles- no withholding taxes on dividends, interest or royalties; 10 year tax holiday on stamp duty on transfers, Trade Tax on imports of office equipment, Social Security tax, Immigration Permit fees

Double Tax Treaties
Seychelles has embarked on an active programme of negotiating double tax treaties with its business partners, which afford the usual benefits in terms of reduced withholding taxes on dividends, interest and royalties. As a recent SIBA Newsletter states:

"An area that is now being given particular attention and emphasis is the development of of a network of double taxation avoidance treaties, an essential element of some of our financial structures and cross-border trading..."
(Seychelles International Business Focus, Vol. 4, Issue 2, page 2.)

The following is a progress list of treaties:
Ratfied In Force: China, Indonesia, South Africa, Oman, Zimbabwe, Thailand, Malaysia and Mauritius
Signed: Namibia
Negotiations Concluded: Russia, Vietnam, Botswana and Egypt
Negotiations in Progress: Tunisia, Cyprus, India, Czech Republic, Malta, Kuwait and UAE
Agreement to Negotiate: Sweden, Qatar, Philippines, Ivory Coast, Tanzania and Kenya

Free Trade Zone (SITZ)
Seychelles is conveniently located as a trans-shipment and redistribution centre for businesses concerned in the Asia/Africa/Middle East markets. The free trade zone operates under the statutory mandate of the Seychelles International Trade Zone Act 1995 and offers modern facilities with attractive tax and other incentives for manufacturing, light assembly and distribution of goods. Other activities such as management consultancy and telecommunications are being encouraged in the Zone.

Portcullis TrustNet (Seychelles) Ltd has experience in setting up CSL's in Seychelles to utilize the treaty route benefits.