Seychelles is an independent Republic within the Commonwealth with a population of 82,000. Seychelles comprises a group of approximately 115 islands in the Indian Ocean. The Seychelles Legislature has enacted legislation providing political stability which facilitating variety investment opportunities.
The Legal System based on English Common Law and French Civil Law. Company and financial services legislation is heavily based in English Law.
There is Chinese (PRC) Embassy located in Seychelles.
The Category 1 Special License Company (“CSL”) is a tax resident Company and may carry on “permitted” business inside as well as outside Seychelles. CSL are normally for accessing Double Tax Treaties. The Category 2 International Business Company (“IBC”) are used like the British Virgin Islands (BVI) IBC’s.
CSL company is a domestic company which is granted a special licence under the Companies (Special Licences) Act 2003. The CSL has access to Seychelles’ steadily expanding Double Tax (“DTA”) network including China, Indonesia, Thailand, Malaysia, South Africa, Botswana, Mauritius, Oman, Cyprus, UAE and Vietnam.
CSL company is liable to business tax at the rate of 1.5% on its worldwide taxable income, however, in every “DTA access” case where foreign tax is paid of an amount higher than 1.5%, such that the foreign tax credit will be set off against, and discharge in full, all Seychelles business tax liability.
The Seychelles / China DTA caps the Chinese withholding tax payable on repatriated dividends at 5%; and the Chinese withholding tax payable on royalties at 10%.
CSL company must have at least two local directors to access the treaty network and two shareholders. Corporate directors are not permitted. Local secretary is also required and the company must prepare and file audited accounts each year. The filed accounts and company return are not publicly accessible. Bearer shares are not permitted and at least 10% of the authorized capital must be issued and paid up.
IBCs are required to have at least one director and one shareholder. Corporate directors and Corporate shareholders are permitted. Company secretary is not required.
Both English and Chinese company name can be included on the company’s Certificate and Incorporation, and Bearer shares are permitted.
IBCs do not have to hold Annual General Meetings nor to file any annual returns, accounts, or financial statements.
|CSL AND IBC||An IBC can be converted to other resident companies such as CSL company.|