Our client recently encountered a bank requirement to provide a tax number for their Seychelles company during the account opening process. However, a Tax Identification Number (TIN) is not automatically assigned to all legal entities in Seychelles. In response to our firm’s inquiry, the Seychelles Revenue Commission (SRC) has clarified the specific circumstances under which an International Business Company (IBC) is eligible to obtain a TIN.
- Seychelles IBCs do not receive a TIN automatically.
- An IBC is issued a TIN only if it generates income within the territory of Seychelles.
- IBCs that derive income exclusively from outside Seychelles are not assigned a TIN.
- A TIN may be required by banks for account opening and CRS self-certification purposes.
- The presence or absence of a TIN does not affect the tax residency status of a Seychelles entity, which can instead be confirmed via a Tax Residence Certificate.
When a Seychelles company is issued a TIN
According to information provided to us by the SRC, International Business Companies are required to register for tax and obtain a Tax Identification Number (TIN) exclusively when they derive income from Seychelles-sourced activities. Specifically, this applies when the company:
- Conducts business activities within the territory of Seychelles;
- Utilizes goods located within the territory of Seychelles;
- Exercises rights within the territory of Seychelles;
- Employs staff working within the territory of Seychelles;
- Or is a member of a Multinational Enterprise Group (MNE Group).
For other IBCs requesting a TIN — for instance, for banking purposes — but who derive their income from sources outside Seychelles, the SRC can only issue a Tax Residence Certificate.
Why Seychelles IBCs Are Not Assigned a TIN by Default
Seychelles companies do not receive TINs automatically upon registration. According to Section 35 of the Revenue Administration Act (2009), the SRC assigns a TIN to persons (entities) obligated to pay taxes, either upon their application or at the Commission’s own initiative. In other words, only companies that qualify as taxpayers within the Seychelles are eligible to claim a TIN.
As a general rule, Seychelles IBCs are only required to pay tax on income derived from sources within Seychelles. Foreign-sourced income is exempt from taxation. The only exception is foreign passive income earned by a Seychelles IBC that is a member of a Multinational Enterprise Group but lacks adequate economic substance in Seychelles. In such cases, this income is deemed to be derived from sources in Seychelles and is taxed accordingly.
Consequently, in the absence of income from local sources, a company does not (and is not required to) obtain a TIN, which is fully compliant with local legislation.
Why Do Banks Request a TIN?
When opening both corporate and personal accounts, banks in various jurisdictions may request a TIN as part of standard “Know Your Customer” (KYC) procedures, as well as for the Automatic Exchange of Information (AEOI) under the Common Reporting Standard (CRS).
In banking self-certification forms for CRS purposes, the following information is typically required:
- The client’s country of tax residence (one or more); and
- The Taxpayer Identification Number in each such country (TIN or its equivalent).
If a company does not have a TIN, the client is usually asked to specify one of three possible reasons for its absence:
- The country in which the client is a tax resident does not issue TINs to its residents.
- The client is unable to obtain a TIN or its equivalent. In this case, the specific reason for this inability must be provided.
- Disclosure of a TIN is not required (if the laws of the client’s country do not require financial institutions to collect and report TIN information).
TIN and Tax Residency Certificate
In the case of IBCs discussed, the inability to obtain a TIN stems from how SRC classifies companies based on the territorial source of their income. Although the law provides for a TIN in Seychelles, the policy for assigning one focuses specifically on whether or not the company has a domestic tax obligation.
However, for a company (including an IBC) to be recognized as a tax resident of Seychelles, the mere fact of its incorporation in Seychelles is sufficient (Article 2 of the Business Tax Act 2009). Any IBC can obtain a Tax Residence Certificate, which is issued by the SRC and is valid for one year. This certificate serves as official confirmation that the company is a tax resident of Seychelles, regardless of whether it has a TIN.
About International Business Companies in Seychelles
IBCs are the premier vehicle for offshore company formation in Seychelles when operations are conducted exclusively outside the jurisdiction. Under the country’s territorial tax system, these companies benefit from a full exemption on foreign-sourced income. It is important to note, however, that tax obligations may still arise in jurisdictions where the company physically operates or where its controlling persons maintain tax residency.
At the same time, the International Business Companies Act 2016 significantly expanded the scope of domestic activity for IBCs by removing most prior restrictions. Currently, they are permitted to own and lease local real estate, be shareholders in other Seychelles companies (whether local or IBCs), maintain a local office and enter into transactions with local residents. However, should they engage in such activities, they will indeed be required to obtain a TIN in Seychelles and file tax returns.
