Company Special Licence (CSL)
Company formation in Seychelles
The CSL is best suited for: Companies that need access to Seychelles double tax treaties, Holding companies seeking treaty-based withholding tax reduction, Businesses requiring a structure with more substance and credibility than an IBC, Regional headquarters for Indian Ocean and East African operations. CSL companies pay corporate tax at 1.5% on assessable income from qualifying activities. The company has access to Seychelles' double tax treaty network and can benefit from reduced withholding tax rates under applicable treaties. Annual tax returns and audited financial statements must be filed with the Seychelles Revenue Commission. The company must demonstrate ongoing substance in Seychelles to maintain the CSL.
- Companies that need access to Seychelles double tax treaties
- Holding companies seeking treaty-based withholding tax reduction
- Businesses requiring a structure with more substance and credibility than an IBC
- Regional headquarters for Indian Ocean and East African operations
Key Facts
Step-by-Step Formation Process
Incorporate a Seychelles domestic company
Incorporate a standard Seychelles company under the Companies Act. This is the base entity that will apply for the CSL designation.
Apply for the CSL from the FSA
Submit a CSL application to the FSA including a business plan, details of proposed activities, KYC documentation, and evidence that the company will meet substance requirements.
Meet substance requirements
Demonstrate adequate substance in Seychelles — a physical office, local employees or management, and board meetings held in the jurisdiction. The FSA reviews substance annually.
Receive the CSL and begin operations
Once approved, the company operates under the CSL regime with access to Seychelles' treaty network and pays the reduced 1.5% corporate tax rate.
Required Documents
- Certified passport copies of all directors, shareholders, and beneficial owners
- Proof of residential address for all parties
- Business plan detailing activities and target markets
- Evidence of Seychelles substance (office lease, employment contracts)
- Source-of-funds declaration
- CSL application form
Cost Overview
Tax Treatment
CSL companies pay corporate tax at 1.5% on assessable income from qualifying activities. The company has access to Seychelles' double tax treaty network and can benefit from reduced withholding tax rates under applicable treaties. Annual tax returns and audited financial statements must be filed with the Seychelles Revenue Commission. The company must demonstrate ongoing substance in Seychelles to maintain the CSL.
Pros & Cons
- Access to Seychelles double tax treaty network (unlike the IBC)
- Very low corporate tax rate of 1.5% on foreign-source income
- More credible than an IBC for dealings with institutional counterparties
- Can conduct limited business within Seychelles
- Flexible corporate structure under the Companies Act
- Higher setup and annual costs compared to an IBC
- Requires genuine substance — office, local management, employees
- Annual audited financial statements and tax filing required
- Smaller treaty network compared to Mauritius or Singapore
- Fewer professional services providers compared to larger IFCs
Other Structures in Seychelles
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