Seychelles TIEAs: Scope, Process, and Confidentiality

What a TIEA Means for a Seychelles StructureCopy link to section

A Tax Information Exchange Agreement (TIEA) is a bilateral treaty that lets one country ask another for specific tax records on a named taxpayer. For a foreign owner, the practical meaning of TIEAs in Seychelles is straightforward: an offshore company in the islands does not place its records beyond the reach of a home-country tax authority that holds such an agreement.

The Seychelles Revenue Commission (SRC) acts as the competent authority for these requests and for the country's wider commitments under the OECD Global Forum. This applies to non-resident shareholders, investors, and the advisers structuring entities such as International Business Companies.

This article explains the country's exchange network, the legal machinery behind it, what information can travel across borders, and how the islands rate against international transparency standards. It is most useful to a foreign business owner or adviser weighing the disclosure exposure of an entity formed there.

How TIEAs Differ from Double Tax Treaties and CRSCopy link to section

The defining feature of a TIEA is that information moves only when one tax authority formally asks for it. This "on request" model implements the OECD's Exchange of Information on Request (EOIR) standard, which traces back to the 1998 OECD report on harmful tax practices and the model instrument that followed in 2002.

A Double Taxation Convention does something different. Its main job is to divide taxing rights between two states and remove the double taxation of cross-border income; an exchange clause usually sits inside it, but as one article among many rather than its purpose.

The Common Reporting Standard works in the opposite direction to a TIEA. Under CRS, financial institutions report account data that tax authorities then exchange automatically each year, with no individual request triggering the flow.

FATCA forms a separate track again. That United States regime requires foreign financial institutions to report US account holders to the IRS, directly or through an Intergovernmental Agreement, and it runs alongside TIEAs without depending on them.

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Seychelles' TIEA Network: Partners and CoverageCopy link to section

The exchange-of-information network reaches 45 jurisdictions. Of these, 28 are covered by Double Taxation Conventions and 13 by standalone TIEAs.

Confirmed TIEA partners include Denmark, the Faroe Islands, Finland, Greenland, Guernsey, Iceland, India, the Netherlands, Norway, Sweden, and Switzerland. The first such agreement was signed with the Netherlands in August 2010 and entered into force on 14 May 2012, with several others concluded in the same period.

A signed agreement with the Cayman Islands dates from 12 February 2014. The SRC's official portal records 13 TIEAs in total, a count slightly higher than older third-party lists, reflecting later signings.

The reach goes well beyond bilateral agreements. The islands signed the Convention on Mutual Administrative Assistance in Tax Matters (MAAC) in 2015, a multilateral instrument with more than 100 signatories that widens exchange relationships far past the 13 TIEAs.

One absence matters for many readers: as recorded in March 2020, no bilateral tax treaty of any kind links the United States and Seychelles. US exposure runs instead through the FATCA channel.

The Legal Framework Behind Seychelles' Exchange CommitmentsCopy link to section

Domestic exchange obligations rest on the Revenue Administration Act, the SRC's governing statute, supplemented by Statutory Instrument 1 of 2015 for CRS reporting. Each individual TIEA is brought into domestic effect through its own ratification legislation.

The SRC carries designated competent-authority status across the full range of obligations: EOIR, CRS, Country-by-Country Reporting, and FATCA. Supervision of anti-money-laundering controls sits with the Central Bank of Seychelles and the Financial Services Authority, under an AML/CFT Act applicable since 28 August 2020 that was drafted partly to close gaps flagged against FATF and EOIR benchmarks.

Several reforms have tightened the framework that makes ownership data available for exchange:

• The Beneficial Ownership (Amendment) Act 2025 (Act 18 of 2025).
• The Revenue Administration (Common Reporting Standards) (Amendment) Regulations 2025 (SI 9 of 2025).
• Amendments to the International Business Companies Act addressing nominee arrangements.

Those IBC changes bear directly on foreign owners. Since December 2024, the register of members must identify the nominator behind any nominee member; from 15 July 2025, a nominee must file a declaration with the company within 21 days of appointment confirming the nominee relationship and the nominator's identity.

Failure to meet the register-of-members rules can draw penalties of up to USD 10,000 against the company and its directors. In 2025 the SRC's compulsory powers were reinforced again, with administrative penalties introduced against information holders who refuse to hand over requested data.

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Scope of Information That Can Be RequestedCopy link to section

The governing test is "foreseeably relevant" information, the standard phrasing in OECD-model TIEAs. The India agreement is representative: assistance covers anything foreseeably relevant to assessing, collecting, or enforcing tax, and to investigating or prosecuting tax matters.

Two principles widen the scope. Information must be supplied regardless of whether the requested country needs it for its own purposes, and regardless of whether the conduct under investigation would be a crime under local law.

In practice, the categories reached under such agreements include:

• Bank account details
• Beneficial ownership of companies
• Accounting records and financial statements
• Identity of shareholders and directors
• Details of trust arrangements

A known weak point concerns nominee structures. The 2026 OECD review noted that ownership information for some entities still needs improvement where nominee arrangements could mask the real owner of shares, which is precisely why the recent IBC amendments target nominator disclosure.

How an Exchange of Information Request Works in PracticeCopy link to section

Requests pass strictly between competent authorities, with the SRC receiving and answering incoming requests for the islands. A requesting authority must name the taxpayer, describe the information sought, state the tax purpose, and explain why the data is believed to be held locally.

These conditions are the standard OECD-model requirements, and they block requests that do not identify a specific subject. The SRC then gathers the material from the relevant holder and responds to the requesting authority.

Response performance has improved but remains imperfect. Across the 2022 to 2024 review period, a full response failed to materialise in 15 percent of cases, against 55 percent in the previous period.

Accounting information is where delays concentrate. The 2026 review singled out the response rate for such records as the area still needing work.

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Confidentiality and Limits on the Use of Disclosed InformationCopy link to section

Information received under a TIEA is confidential. It may reach only the persons and authorities concerned with assessing, collecting, enforcing, prosecuting, or deciding appeals on the taxes the agreement covers, and only for those purposes.

Disclosure in open court or in a published judicial decision is permitted. Beyond that, the data may not pass to any other person, authority, or jurisdiction without the express written consent of the requested party's competent authority.

The FATCA IGA mirrors this language for US exchanges. Where the islands give prior written consent, information may also be used for purposes allowed under a mutual legal assistance treaty in force between the two states.

The "foreseeably relevant" test serves as a procedural filter against fishing expeditions: a requesting authority cannot seek records on an unnamed category of taxpayers. Domestic confidentiality duties under the Revenue Administration Act and the AML/CFT Act bind the SRC in parallel with the treaty text.

TIEAs and Seychelles' Standing Against OECD Transparency StandardsCopy link to section

Membership of the Global Forum on Transparency and Exchange of Information for Tax Purposes dates from 2009. The most consequential recent development is the EOIR rating: following reforms since the 2020 second-round review, the islands were reassessed as Largely Compliant, published on 21 January 2026.

That is an upgrade from the Partially Compliant rating that had applied after the 2020 review and a 2023 supplementary review. To reach full effectiveness, supervision and enforcement around the availability of and access to information must continue.

European Union listing tells a parallel story. In October 2023 the Council added the islands to Annex I, the non-cooperative blacklist, citing a shortfall on exchange of tax information on request.

The move to Annex II reflects a commitment to fix the remaining deficiencies in time for the Global Forum AEOI peer review in 2026, not a complete delisting. Ahead of the in-depth review, the Global Forum Secretariat ran a mock on-site visit in Victoria in February 2025, with a further visit in May 2025 to prepare for the CRS effectiveness review.

What This Means for a Non-Resident Owner or AdviserCopy link to section

Offshore status alone offers no shield. If your home tax authority holds a TIEA with the islands, or reaches them through the MAAC, it can request specific records about your company or account.

The practical reach is broad: 45 jurisdictions through DTCs and TIEAs combined, plus the 100-plus MAAC signatories. CRS adds an automatic layer, with local financial institutions reporting to the SRC for onward exchange since the first reporting in 2017, and the FATCA IGA signed in July 2019 routes US-person data to the IRS.

• Nominee shareholders must now disclose nominator identities on the register of members, so nominee structures no longer conceal beneficial ownership at the corporate register.
• Penalties of up to USD 10,000 apply for deliberate breaches of the register rules, giving the SRC leverage to keep ownership data available.

For advisers, two points carry weight. The "Largely Compliant" rating with a 15 percent failure rate signals improved but still imperfect exchange that may slow rather than block a legitimate request, and the October 2025 Annex II status means some EU-regulated counterparties may apply enhanced due diligence to local structures.

Outlook for Information Exchange in SeychellesCopy link to section

The direction of travel is toward firmer enforcement. The January 2026 upgrade to Largely Compliant reflects genuine legislative and administrative reform, and the 2025 introduction of administrative penalties against uncooperative information holders adds teeth whose effect is still being monitored.

Removal from the EU grey list depends on satisfactory results in the Global Forum AEOI peer review expected in 2026, for which the CRS effectiveness on-site visit was scheduled in July 2025. The accounting-information response rate is the weakness most likely to attract continued SRC attention and guidance.

New bilateral TIEAs are unlikely to multiply. With the MAAC now the preferred multilateral vehicle worldwide, standalone agreements have become less common, and no specific new negotiations are confirmed.

ConclusionCopy link to section

A foreign-owned entity in the islands operates inside a wide and tightening exchange-of-information system, reachable through 13 TIEAs, 28 DTCs, the MAAC, CRS, and the FATCA channel. Recent reforms to beneficial ownership and nominee disclosure mean ownership data is increasingly available to the SRC for exchange, and the upgraded OECD rating confirms the trend. The sensible course is to structure and report on the assumption that legitimate requests will eventually be answered, and to keep accounting records complete and current. Watch the EU grey-list status, since it can affect how regulated counterparties treat your structures.

How Expanship Can Help Your Business in SeychellesCopy link to section

Expanship supports foreign owners and advisers in understanding how the TIEA network, CRS, and beneficial-ownership rules apply to a specific structure, and in keeping registers and records aligned with what the SRC may be asked to produce. That advisory work sits within a wider set of services for running a compliant entity in the jurisdiction.

• Company formation and entity structuring
• Registered agent and registered office
• Tax registration and return filing
• Ongoing compliance and statutory record management
• Accounting and bookkeeping
• Introductions to banking partners

To discuss your structure or compliance needs, contact Expanship Seychelles.

Frequently Asked QuestionsCopy link to section