Special License Company
A Seychelles Special Licence Company (CSL) gets incorporated under the Companies Act 1972, governed by the companies ‘Special License Act 2003’. Such entity is mainly used for investment in countries with which Seychelles has a tax treaty. CSL is mainly used to engage in trading activities where there will be multiple global counterparties in different countries.
A Seychelles CSL that meets certain requierements qualifies for access to the network of Double Taxation Avoidance Agreements (“DTAAs”) entered into between the Government of Seychelles and various treaty partner countries such as China, Indonesia and South Africa among others.
Additional Info
Activities of a Special License Company
Investment banking and advice
Offshore banking
Offshore insurance and reinsurance
Holding company
Special License Company (CSL) and International Business Company (IBC) – Comparison
The Seychelles Financial Services Authority (FSA) is the regulator of the non-banking financial sector. The main difference between the two companies is that CSL is deemed tax resident in Seychelles and enjoys the benefits of double taxation treaties.
| CSL | IBC | |||
| Residence | Seychelles, for tax purposes | No | ||
| Double taxationtreaty access | Yes | No | ||
| Corporation tax on worldwidenet income | 1.5% maximum effective rate | No | ||
| Double taxationtreaty access | Exempt | Exempt | ||
| Withholding tax on dividends, interest and royalties | Exempt | Exempt | ||
| Stamp duties on any property or share transfers and transactions | Exempt | Exempt | ||
| Requirements | CSL | CSL | ||
| Minimum number of directors | 2, for tax purposes | 1 | ||
| Minimum number of shareholders | 2, corporate or individual | 1 | ||
| Accounts | Prepare and submit unaudited accounts | Useless filling | ||