Subject: Further guidance for International Business Companies (IBC) in Seychelles

Dear Client,

This update summarizes the recent guidance released by Seychelles Revenue Commission (SRC) about the taxable income and Tax Identification Number of IBC in Seychelles.

(1) Seychelles-sourced income are taxable in Seychelles

According to the recent guidance on taxable income, any IBC which derives Seychelles-sourced income according to the definition outlined in the Guidance Notes would be taxable in Seychelles. An additional statutory obligation would be imposed to the IBCs with Seychelles-sourced income, such as annual preparation and filing of audited accounts and tax returns.

For better understanding of whether an IBC falls within this scope, you are encouraged to share the Business plan with us. If your IBC is indeed earning Seychelles-sourced income, the directors of the company must inform the IBC Registry within 30 days of such occurrence. Therefore, you should inform us within 14 days of such occurrence to enable us to assist you in notifying the Registry in a timely manner.

(2) Applying for a Tax Identification Number (TIN)

We are pleased to inform you that following legislative changes in Seychelles, from now on any active Seychelles company with good standing status as well as maintaining its accounting records in Seychelles, preferably at the Registered Office (RO) of the IBC will be able to obtain TIN Number, regardless of whether it derives Seychelles-sourced income. Please note that TIN applications can only be processed by your current Registered Agent.
Currently, the TIN applications can only be performed manually but we expect that an online portal would be finalized by the Department of Information Communications Technology (DICT) within next few months.

In order to apply for a TIN, IBCs will have to carry out the following:

• Provide a Certificate of Good Standing (CGS) (NB: This will not be necessary once the online portal is rolled out, as the SRC will be able to ascertain an IBC's legal standing through a direct live link with the Registry's database.);
• Provide a supporting directors' resolution reflecting its RO address as the physical location of its accounting records;
• Pay an initial filing fee to start maintaining its accounting records electronically at RO as well as Kaizen. Subsequently, an annual filing fee will be due and payable together with its annual renewal invoice;
• Submit a copy of all its accounting records* electronically for maintenance by RO as well as Kaizen, which can be accessible by the SRC upon request.

We strongly recommend you to take actions at the earliest in making a professional determination on whether your IBCs derive Seychelles-sourced income and inform us promptly if this is the case.

Yours sincerely,
The Kaizen Team

*We wish to remind you of provisions of the IBC Act, pertaining to the type of accounting records expected to be maintained by all IBCs for a minimum period of 7 years from the date of a particular transaction