Personal tax residence and income scope

Residence has several alternatives

Under the Business Tax Act definition, an individual is resident if they reside in Seychelles, have Seychelles domicile unless they have a permanent abode abroad, or are present for at least 183 aggregate days in any twelve-month period starting or ending in the tax year. 'Resides' includes normal residence, residence for at least 183 days in a tax year, or domicile; fewer days alone do not settle the question.

Citizenship appears in the domicile definition

The Business Tax Act defines an individual's domicile by long-term residence or Seychelles citizenship unless the Revenue Commissioner is satisfied that the person is not domiciled there. This qualification and the permanent-abode exception require individual assessment; nationality is not a blanket conclusion about worldwide tax liability.

Employment and employer-provided benefits

SRC describes tax on employees' emoluments collected through employer withholding. It separately makes non-monetary benefits tax an employer liability, subject to exemptions, and distinguishes citizen and non-citizen employee rate schedules. These categories do not amount to a tax-free-passport rule.

Source-based individual business income

Business tax also applies to sole traders. Amended section 5(1) treats business income of a resident person other than a covered company as Seychelles-sourced when it comes from activities conducted, goods situated or rights used there. The wider foreign-income and economic-substance provisions are for covered companies; a foreign customer or offshore payment alone does not establish that locally performed work is foreign-sourced.

Non-resident payments and treaties

SRC identifies withholding on Seychelles-source interest, dividends, royalties, technical or managerial service fees and natural-resource payments to non-residents. The payer must consider permanent-establishment rules and the applicable double-taxation agreement; income subject to final withholding is not also liable to business tax under that guidance.