Seychelles Special License Company (CSL)

Seychelles Special License Company – abbreviated as “CSL” – is a domestic Limited Company that is granted a “Special License” by the Seychelles International Business Authority, conferring upon it a unique tax status. This innovative entity was introduced under the Seychelles Companies (Special Licenses) Act of 2003 and, while more intricate and costly compared to the traditional IBC (International Business Company), offers several notable advantages.

The most compelling feature of the Special License Company is its ability to circumvent international blacklisting by maintaining a low-tax status, as opposed to the zero-tax status of an IBC. Additionally, a CSL is eligible to utilize the increasing number of double taxation avoidance treaties that Seychelles has entered into. These treaty benefits are not accessible to IBCs. Unlike an IBC, a CSL is formally recognized as a tax resident in Seychelles, which facilitates smoother international business operations, attracting less scrutiny and suspicion.

The formation of a CSL is carried out in accordance with the general provisions of the domestic Seychelles Companies Act of 1972, with its unique tax regime and other distinctive attributes governed by the Seychelles Companies (Special Licenses) Act of 2003.

Relevant Features

Low Taxation

Unlike an IBC, which enjoys zero-tax status, a Special License Company is subject to a 1.5% tax on its worldwide income. Furthermore, a CSL is exempt from withholding taxes on dividends, interest, and royalties, as well as from stamp duties related to property or share transfers and transactions.

Tax Treaty Benefits

In contrast to an IBC, a CSL qualifies as “tax-resident” in Seychelles, granting it access to an expanding network of international Double Taxation Avoidance Treaties (DTAs). Seychelles has ratified DTAs with various nations, including China, South Africa, Indonesia, Thailand, Oman, Botswana, and Mauritius. Agreements with Belgium, Cyprus, Malaysia, Vietnam, and Zimbabwe have been signed, and negotiations for DTAs with Egypt, UAE, Russia, Bahrain, Czech Republic, Tunisia, Namibia, and Kuwait have been concluded.

Special Operational Activities

A Special License Company is the ideal vehicle for businesses requiring specific regulation. It can engage in activities such as investment management and advice, offshore banking, offshore insurance and re-insurance, investment services, holding, marketing, intellectual property and franchise, human resources, and can function as a headquarters or holding company. Additionally, CSLs are authorized to operate under the Seychelles International Trade Zone License. The law also allows CSLs to engage in other businesses that gain approval from the Seychelles International Business Authority, encompassing traditional activities like international trade in goods and service provision.

Important Note

Although the general provisions of the Companies (Special Licenses) Act of 2003 permit CSLs to engage in offshore banking and insurance activities, participation in these specific activities necessitates additional licensing from the Central Bank or other relevant government authorities.

Application procedure

The establishment of a Special License Company is not a standardized, one-size-fits-all procedure. It necessitates the meticulous preparation of an extensive application submitted to the Seychelles International Business Authority (SIBA). This application process entails a comprehensive collection of information from the client, who is typically the beneficial owner of the company.

In addition to the formal documents, which we typically assist in preparing independently, the CSL Application dossier must include a detailed business plan outlining the company’s objectives, the specific nature of its operations, a 3-year financial forecast, market descriptions, marketing strategies, and capitalization details. This crucial information can only be provided by the client.

Upon the issuance of the Certificate of Incorporation by the Registrar, the new company will come into existence. Subsequently, based on the information submitted during the initial CSL Application, SIBA will grant the new company a Special License, transforming it into a fully recognized Special License Company.

Confidentiality

The formation of a Special License Company is not a discreet process. During the Special License Application, the actual beneficial owners of the CSL must be identified. A comprehensive business plan and extensive personal details are required for submission. However, it is important to note that this information remains confidential within the Seychelles International Business Authority and is not accessible to the public or disclosed to foreign governments. The law includes stringent confidentiality provisions ensuring that all data gathered during the Special License Application process remains strictly confidential.

Unlike some of its counterparts, Seychelles is an independent nation and is not obliged to share or report information to any foreign “principal state” or organization. Seychelles is not subject to the EU Savings Tax Directive, as some other offshore jurisdictions affiliated with EU member states are (primarily the UK and its overseas territories).

These fees are in addition to the professional fees that may be charged by our services for incorporation, assistance with the Special License application process, and company management, as applicable.

How to Begin

If you are considering establishing a Special License Company, we recommend starting by reviewing the Application Guidelines and relevant forms. These resources provide clear instructions on how to complete the necessary documentation.

Seychelles Special License Companies
Key Features