eSwatini has a source-based tax system, in terms of which both residents and non-residents are taxed on income from a source in eSwatini.
The eSwatini Income Tax Order does not provide a definition of the concept of residence, but defines the term “company” as:
- any association incorporated by or under any law in force in eSwatini;
- any association which, though incorporated outside eSwatini, carries on business or has an office or place of business in eSwatini; or
- anybody incorporated by any law in force in eSwatini or in any country outside eSwatini that carries on business in eSwatini.
corporate tax rate
Resident companies and permanent establishments of foreign companies are subject to corporate income tax at the rate of 27.5%.
|capital gains tax|
eSwatini does not tax capital gains.
However, income from the disposal of assets in the normal course of a business activity and income from the non-occasional disposal of assets are included in gross income.
withholding tax (“WHT”) rates
WHT rate (%)
|payment to||residents ||non-residents|
|branch profits||N/A||15% |
12.5% (for CMA head offices)
12.5% (for CMA shareholders)
|management, consulting and technical service fees||N/A ||15%|
| || |
double tax agreements (“DTAs”)
DTAs are in force with Mauritius, South Africa, Seychelles, Taiwan and the United Kingdom.
Losses may be carried forward indefinitely.
eSwatini does not have specific transfer pricing rules. However, in terms of the general anti-avoidance rules, transactions must be entered into on an arm’s length basis.
There are no thin capitalisation rules applicable in eSwatini.
The income tax rates applicable to resident individuals are:
|annual chargeable income (SZL)||tax rate |
|Up to 100,000||20% |
|100 001–150 000 ||SZL20,000 + 25% of the excess over SZL100,000|
|150 001 – 200 000||SZL32,500 + 30% of the excess over SZL150,000|
|Over 200 000||SZL47,500 + 33% of the excess over SZL 200,000|
Both employers and employees must make monthly social security contributions to the SNPF.
Both the employer and employee contribution rates are SZL125 per employee, if the employee earns at least SZL2 500 per month and 5% of the monthly earnings of an employee earning less than SZL2 500 per month.
Expatriates are not obliged to contribute to the SNPF.
|payroll taxes||There is no payroll tax in eSwatini.|
|stamp duty |
Stamp duty is levied on a number of instruments under the Stamp Duties Act, including agreements and contracts, bills of exchange, bonds, leases, insurance policies, debentures and shares.
Stamp duty at the rate of 2% is generally payable on the registration of transfer of marketable securities.
Transfer duty at a rate of between 2 and 6% is levied on the transfer of immovable property, depending on the value of the property, under the Transfer Duty Act.
|taxable supplies ||VAT is levied on the supply of goods and services in eSwatini on and the importation of goods and services.|
A person who supplies taxable goods or services in eSwatini and has an annual taxable turnover exceedingSZL500 000 must register for VAT purposes.
Businesses whose turnover is below the threshold may voluntarily apply for registration, provided any other registration requirements are met.
|reverse VAT on imported services|
To the extent that imported services will be utilised or consumed in eSwatini other than for making taxable supplies, the recipient of such services is required to declare and pay output VAT on the services in terms of a reverse VAT mechanism.
Such reverse VAT is not available as an input credit.