The Special Licence Company (‘CSL’) is a company which is set up under the Companies (Special Licences) Act 2003 in Seychelles. It is widely used in circumstances where tax residency is required in which case an international business (tax exempt) company serves no purpose. The CSL can actually apply for a Tax Residency Certificate with the Commissioner of Income Tax. In that respect, the CSL can benefit from the tax treaties signed by the Seychelles with other countries. Presently, a lot of investors are using the CSL to invest into Indonesia given that the Double Taxation Avoidance Agreement signed between Seychelles and Indonesia is one of the best.

The advantages of using the CSL are not only limited to tax residency issue and tax treaties. Other main advantages are that there is no withholding tax on payment and receipt of dividends, no capital gains tax, no stamp duty and a minimal corporation tax rate of 1.5%. With these benefits, it is obvious that the CSL is a good vehicle as a holding company.

There is a list of activities allowed under a CSL which are Investment management and advice, offshore banking, offshore insurance, re-insurance, investment & holding company regimes, international marketing & distribution, holding intellectual property (licensing/royalties), group headquarters operations, intra-group services provider (like HR, accounting, R&D), franchising, International Trade Zone (“ITZ”) activities and any other business approved by the Seychelles International Business Authority.

Inco Trust can assess whether the CSL can be useful to your organisation and/or business structure and advice on its efficient use.