The Seychelles Company Special Licence (CSL) is a hybrid vehicle — combining IBC flexibility with onshore regulatory recognition, a 1.5% tax rate on worldwide income, and eligibility for Seychelles double tax agreements.
The Seychelles CSL is a regulated business vehicle issued by the FSA, designed for companies requiring access to Seychelles's double tax agreement network while maintaining operational flexibility. Unlike a standard IBC, a CSL is taxed at 1.5% on worldwide income — but gains access to Seychelles's tax treaties, which cannot be accessed by IBCs.
Marensa Advisory advises on CSL formation for clients whose investment strategies require Seychelles DTA access — particularly for investments into Africa where Seychelles has relevant bilateral treaties.
Discuss CSL FormationChoosing between a CSL and a standard IBC depends primarily on whether Seychelles DTA access is needed for your investment strategy.
The CSL's 1.5% tax rate is the price of accessing Seychelles's DTA network. For investment structures where treaty benefits exceed the tax cost, the CSL delivers genuine value..
Marensa Advisory advises on CSL formation as part of cross-border holding structures — ensuring the tax and regulatory benefits are fully captured in the design.
Start the ConversationThe 1.5% rate applies to worldwide income of the CSL. Some income categories may be exempt under Seychelles domestic law or DTA provisions — a qualified Seychelles tax adviser should be consulted for specific income characterisation.
Yes — CSLs can be used to hold investment fund interests, Mauritius GBC shares, or other cross-border investment structures, subject to the qualifying activities assessment.
No. Mauritius has 46+ DTAs; Seychelles has approximately 15. Mauritius remains superior for African investment structures where treaty access is the primary driver. Seychelles CSLs are most useful for specific corridors where Seychelles has relevant treaties (UAE, South Africa, Botswana, China).
CSL formation typically takes 4–6 weeks from FSA application, compared to 24–48 hours for an IBC — due to the FSA regulatory approval requirement.