As of 21 August 2026, the Seychelles Revenue Commission (SRC) announced the immediate suspension of Tax Identification Number (TIN) issuance for International Business Companies (IBCs) not operating within Seychelles and requesting TIN solely for bank-account purposes. This measure arises from amendments to the Seychelles International Business Companies Act and reinforces the statutory requirement that TINs are reserved for entities deriving income sourced in Seychelles, thereby closing a regulatory gap previously exploited for offshore banking structuring without substantive local economic activity. The decision follows consultations with the Financial Services Authority and aligns with the OECD’s Base Erosion and Profit Shifting (BEPS) framework, reflecting the government’s commitment to transparent tax administration and prevention of artificial tax residency arrangements.
Key Takeaways
- TIN Restriction to Income-Sourced Entities: TINs will henceforth be issued only to IBCs conducting genuine business operations or generating Seychelles-sourced income; non-operational IBCs seeking TINs for custodial or banking convenience are explicitly excluded, affecting multinational holding structures.
- Compliance and Penalty Framework: The suspension takes effect immediately; IBCs operating without a valid TIN in financial transactions, including account opening and regulatory reporting, may face penalties, interest on underpayments, and enhanced scrutiny during SRC compliance audits.
- Structural Reassessment for Multinationals: Group entities must reassess their Seychelles subsidiary profiles, document the sourcing of all income, and ensure that any retained TINs correspond to active economic activity, thereby mitigating risks of inadvertent non-compliance in cross-border finance arrangements.
Disclaimer:This article is compiled and summarized based on publicly available information and is for general information and academic exchange purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. For tax planning, please consult a qualified professional tax advisor or legal counsel.
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