Published on and written by Cyril Jarnias
The Seychelles is one of those destinations that makes French individuals dream of sunshine… and sometimes wealth optimization. Territorial tax system, absence of many taxes, clear legal framework for foreign investment: on paper, the archipelago has strong arguments. But as soon as a French person becomes a property owner in Seychelles, a dual reality sets in: local taxation on one side, French taxation on the other, with no bilateral convention to bridge the gap. Understanding this dual environment is essential before buying or transferring a property.
A Seychellois tax system very favorable to investors
The Seychelles has operated since 2010 under a territorial tax system: in principle, only income sourced within the archipelago is locally taxable. Foreign-source income is largely outside the scope of Seychellois tax, subject to economic substance conditions set out in the Economic Substance Act of 2021.
A Seychelles tax resident is only taxed on locally sourced income. Foreign income (pensions, interest, dividends, capital gains) may be exempt subject to meeting substance criteria. The country does not apply wealth tax, inheritance tax, gift tax, general capital gains tax, or annual wealth tax.
The corporate tax framework is also considered attractive. The standard rate is 15% on the first million Seychellois rupees (SCR) of taxable profit, then 25% above that threshold. Certain regulated sectors (particularly financial) may be subject to a higher scale, up to 33%, but this is not the case for “ordinary” companies. Sole proprietors are taxed at 0% up to SCR 102,666, 15% from SCR 102,666.01 to SCR 1,000,000, then 25% above. Small businesses may, under conditions, opt for a 1.5% tax on turnover instead of profit tax.
The standard VAT rate in 2026 is 15%, with a 15% withholding tax on certain payments to non-residents.
For a foreign real estate investor, the key point is the combination of a territorial system, the absence of capital gains tax “as such,” and local taxation concentrated on a few specific taxes, particularly acquisition duties, the annual tax on properties held by non-Seychellois, and taxation of rental income.
Buying real estate in Seychelles: conditions and approvals
For a French person, becoming a property owner in Seychelles is not just about signing a contract on a dream beach. Acquisitions by non-Seychellois are strictly regulated by the Immovable Property (Transfer Restriction) Act. Any foreign individual or legal entity may acquire private real estate in the archipelago, but only with prior government approval via a “sanction” mechanism (authorization).
Authorization must be requested from the Ministry of Lands and Housing, directly or through a Seychellois notary or lawyer, with a file including certified passport, proof of address, criminal record, PPE declaration, source of funds, bank statements, and for companies, articles of association and beneficial owners. Documents not in French or English must be translated with the translator’s contact details.
When granted, the authorization is only valid for one year. The purchase must be signed and registered within this period; otherwise, a new application is required. Certain categories of property remain prohibited for non-Seychellois, notably agricultural land, environmental zones, and subsidized housing. Acquisitions on outer islands or land transferred under public housing programs are also excluded, except for very specific schemes such as certain “Villas Policy” operations.
Since January 2025, non-Seychellois can again buy residential properties, but only in designated areas or approved programs. The minimum price is around SCR 10 million for high-end properties, with minimum plot sizes of 1,000 to 4,000 m² for houses and 2,000 to 4,000 m² for vacant land. Size derogations are possible depending on topography, setbacks, or security.
For condominium apartments, a more incentive-based regime exists: the “sanction duty” (specific approval tax) remains set at 1.5% of market value, but the price per square meter must be at least SCR 30,000, and certain programs related to public or subsidized land are excluded.
The main lines of this framework can be summarized as follows:
| Key elements | Rules applicable to non-Seychellois |
|---|---|
| Prior authorization | Mandatory via Ministry of Lands / SIB |
| Validity period of authorization | 1 year to sign and register the deed |
| Accessible areas | Designated Areas and approved programs |
| Prohibited properties | Agricultural land, environmental zones, subsidized housing, certain state land |
| Indicative thresholds | ≈ SCR 10 M for high-end residences, 2,000–4,000 m² for vacant residential land |
| Condominiums | Sanction duty 1.5% – price ≥ SCR 30,000 / m² |
For a French person, this regulatory dimension is not just a detail: an improperly calibrated authorization or a project outside the framework (e.g., attempting to buy agricultural land or social housing) will simply be blocked.
Acquisition cost: duties, taxes, and fees borne by the French buyer
Beyond the property price, an investor must factor in a relatively substantial transaction cost, mainly consisting of stamp duty, sanction duties, and processing fees. These amounts add up and are largely calculated on the market value of the property (or the transaction price, if higher).
Several components emerge:
Stamp duty amounts to 5% of the real estate transaction amount in Seychelles.
Upfront, simply filing the sanction application incurs a non-refundable flat fee: SCR 3,000 for a purchase, SCR 2,000 for a lease, SCR 1,000 for acquiring shares in a company holding property. Upon approval, additional processing fees are due (1.5% of value for a purchase or lease, SCR 3,000 per file for an equity stake in a real estate company).
For a French person acquiring a villa worth SCR 10 million, the cumulative order of magnitude of duties and fees can quickly rise. A simplified summary, excluding any potential sanction duty at 12%, gives for example:
| Cost item | Basis of calculation | Indicative rate | Amount for a property at SCR 10 M |
|---|---|---|---|
| Stamp duty | Price or market value | 5% | SCR 500,000 |
| Approval tax / basic sanction | Market value | 1.5% | SCR 150,000 |
| Registration fees | Market value | ≈ 1% | SCR 100,000 |
| Notary fees | Sale price | 1–2% | SCR 100,000 to 200,000 |
| Sanction application fee | Flat | SCR 3,000 | SCR 3,000 |
In some cases, especially for residential purchases outside the “Villas” policy, the sanction duty can be raised to 12% of the market price, drastically changing the final bill. Other cases (tourist, commercial or industrial investments, certain group operations, family transfers, marital property settlements) benefit from full or partial exemptions from this sanction duty.
The Stamp Duty Order 2019 provides targeted exemptions (e.g., first purchase of main residence up to SCR 3 million) reserved for Seychellois citizens. These benefits do not apply to a direct French investor, but may concern future restructuring involving a Seychellois spouse or co-heir.
Annual tax on real estate held by non-Seychellois
Since the entry into force of the Immovable Property Tax Act in 2020, any foreigner owning real estate in the Seychelles is, in principle, subject to an annual tax on the value of their property. This levy, initially set at a rate of 0.25% of market value, was raised to 0.50% effective January 1, 2024, and this rate is announced as applicable in 2026.
The tax broadly applies to “all types of buildings”: residences, commercial buildings, industrial assets, villas, condominium units, freehold land, or long-term leases. When the property is co-owned with a Seychellois, the foreigner’s share remains taxable.
The calculation follows the formula T = R × V, with a rate of 0.50% (R) applied to the property value (V) assessed by the land services, revalued every five years. If the property was purchased in foreign currency, conversion into Mauritian rupees (SCR) uses the exchange rate on the date of filing the valuation file.
For a property worth SCR 5 million, the annual charge, at the rate of 0.50%, represents SCR 25,000. By way of indication, at the initial rate of 0.25%, it would have been SCR 12,500.
Payment is due each year before December 31, to the Seychelles Revenue Commission. Failure to register the property or to submit proof of value is severely penalized: SCR 50,000 fine for lack of registration, SCR 3,000 for failure to submit the valuation report.
Certain categories of buildings are exempt, notably:
– buildings used for commercial or industrial purposes;
– residences owned by foreigners married to a Seychellois, as long as the marriage lasts (or when the Seychellois spouse dies while still owner);
– buildings or parts of buildings used exclusively for employee housing;
– properties dedicated to wildlife or natural habitat conservation;
– buildings owned by foreign states for diplomatic use;
– properties seized or awarded to financial institutions in the context of mortgage foreclosure;
– properties owned by a minor foreigner adopted by a Seychellois.
For a French investor, this annual tax represents a moderate but real recurring cost, fairly comparable in order of magnitude to a small property tax. It adds to other charges (maintenance, management, insurance) and must be factored into the net return of the project.
Rental income and taxation of real estate income in Seychelles
Rental income is also taxable in Seychelles as long as it derives from a property located there. The country applies a rate of 15% on rents, considered relatively low. From a VAT perspective, residential rents are expressly exempt, while commercial rentals may fall within the scope of VAT when turnover exceeds a certain threshold.
For companies operating professionally with multiple rental properties, rents are subject to Business Tax according to the general scale: 15% on the first million SCR of profit and 25% above. Rental income may also trigger withholding tax for non-residents, but the base rate is 15% on rental income.
Seychellois taxation also distinguishes between residential and commercial rentals. For commercial buildings, rental income is treated as business income and taxed at the standard Business Tax rates. Sectoral information also mentions a limitation of residential rent taxation to 3% of gross income in some cases, but the stabilized and directly usable element for an investor remains the rate of 15% on rental income, absent a specific structure.
Here again, for a French person, the main issue is not so much the amount of tax in Seychelles (modest) but its articulation with French tax, in the absence of a double taxation avoidance agreement.
Capital gains on real estate in Seychelles: an advantage, but not a global exemption
One of the arguments often put forward for the Seychelles is the absence of a true specific capital gains tax (CGT) in domestic law. In practice, this means that the resale of a villa, apartment, or land is not subject to a standalone local capital gains tax, unlike many countries.
Gains from asset disposals are taxable if they form part of a property trading or dealing activity.
A developer or property trader engaging in multiple buy-sell transactions sees gains treated as business profits.
These profits are taxable under Business Tax, at a rate of 15% or 25% depending on the case.
For the individual wealth investor, who buys a second home or rental property and resells it a few years later, the Seychelles reality is therefore close to a 0% regime on capital gains, except in the special case of reclassification as a commercial activity. This point is central to the perception of the destination as a “soft tax jurisdiction” for real estate.
But this reading only holds locally. For a French tax resident, any capital gain realized in Seychelles remains, in principle, subject to French tax, as France applies the rule of worldwide income taxation for its residents. This is where the absence of a tax treaty with the Seychelles becomes decisive.
No tax treaty between France and Seychelles: consequences for the French
Unlike other states with which the Seychelles has signed bilateral double taxation avoidance agreements (China, United Arab Emirates, Singapore, South Africa, etc.), there is currently no tax treaty between France and the Seychelles. This absence leads to two sets of major consequences for a French investor.
Any French tax resident must declare and pay tax in France on their worldwide income, including that from a foreign real estate property (rents, capital gains), under Article 4 A of the French General Tax Code (CGI). Taxation abroad does not exempt from these obligations, and in the absence of a tax treaty, no tax credit is guaranteed to avoid double taxation.
Furthermore, the logic of typical OECD conventions, which generally allocate the taxation of real estate income to the country where the property is located, cannot be invoked for the Seychelles. In practice, French domestic law applies without a treaty correction. Doctrine recalls that when no treaty exists, income is, by default, taxable in France, even if already taxed abroad.
For a French owner in the Seychelles, this very concretely means:
Rents received in Seychelles must be declared as rental income in France, without exemption related to a local 15% tax. Disposal capital gains, even if not taxed locally, fall under the French regime for foreign-source real estate capital gains with allowances and social contributions. No automatic treaty tax credit is granted in case of double taxation.
The general French mechanisms do provide for the possibility of tax credits in some cases, but these are normally governed by a treaty. Without a bilateral text, the taxpayer ends up in a purely unilateral scheme where France will, in practice, tax the entire base, while at best allowing the deduction of certain charges and the application of standard allowances.
Taxation in France of rents from a property located in Seychelles
From the French tax administration’s perspective, rents from an unfurnished property located abroad fall under the category of rental income (revenus fonciers). It does not matter whether the property is in London, Lisbon, or Mahé: a French tax resident must declare them.
Two main regimes exist for unfurnished rentals:
For rental income received in 2025 (declared in 2026): if the gross total does not exceed €15,000, the micro-foncier regime applies with a 30% allowance and simplified declaration on form 2042. Above €15,000 or by option, the actual (real) regime is mandatory, allowing deduction of actual expenses (loan interest, works, insurance, property tax, management fees) via a supplementary form 2044.
The rental income thus calculated is subject to the progressive income tax scale, to which are generally added social contributions at a global rate of 17.2%. Rental deficits (mainly from works, excluding loan interest) are deductible from overall income up to €10,700 per year, with the surplus carried forward against rental income for the next ten years.
For a French owner, the rent received in Seychelles is first taxed locally (potentially reduced by 15%), then declared in France as gross rental income without deducting the Seychellois tax, due to the absence of a treaty. This leads to potential double taxation.
Real estate capital gains: local exemption, full taxation in France
On the resale of a property located in Seychelles, the Seychellois administration does not levy a specific capital gains tax in most private situations. On the French side, however, a capital gain realized by a tax resident is in principle taxable, even when the asset is located outside France.
The French real estate capital gains regime then applies, with:
Real estate capital gains are exempt from social contributions after 30 years of ownership.
In this context, the Seychelles advantage (absence of local capital gains tax) only avoids double taxation at the source level. France will nonetheless tax the entire net gain calculated according to its own rules (sale price, acquisition cost increased by expenses and works, allowances, possible surtax for large gains). Without a treaty, no tax credit automatically neutralizes any potential foreign tax, even if, in this case, the local capital gains tax is zero.
French non-residents for tax purposes remain taxable in France on capital gains from the sale of properties located in France, but not on those realized in Seychelles, as their center of economic interests is no longer in France.
Transfer of a property in Seychelles: no local inheritance tax, but French vigilance
Another aspect that attracts investors is the absence of inheritance tax in Seychelles. No inheritance tax is due there, whether on movable or immovable property, and no general gift tax exists. However, transferring a local real estate property to a foreign heir remains subject to specific fees and, above all, administrative control.
Any inheritance transfer to a non-resident requires authorization from the Seychelles Investment Board and the Land Registry. The heir must provide the death certificate, proof of their status, and an application for approval. A local lawyer or notary is almost indispensable for the formalities, especially in case of co-ownership or split ownership.
Some texts mention the application, in certain cases, of a 5% duty on inheritance transfers to foreigners, resembling the 5% stamp duty rate on transfers. For a French national inheriting a property in Seychelles, this local charge, even moderate, adds to a second, much more sensitive component: inheritance tax in France.
Any heir who has been a French tax resident for at least 6 of the 10 years preceding the death must declare all inherited assets in France, including those in Seychelles. These assets are subject to French inheritance tax without a tax credit, in the absence of a tax treaty between France and Seychelles.
A practical point deserves special attention: any foreigner receiving real estate by inheritance must, like a buyer, obtain an administrative sanction for the title transfer to be fully enforceable. Failing this, the property cannot be validly registered in the heir’s name. For French people wishing to pass on property to children or grandchildren residing in France, coordination between French and Seychellois notaries is therefore crucial.
Structuring ownership: companies, offshore holdings, and French constraints
The Seychelles toolkit includes a regime for International Business Companies (IBCs) largely exempt from tax on their foreign-source profits. These structures are frequently used, in many jurisdictions, to hold real estate abroad or to carry participations in operating companies, notably to simplify resales (transfer of shares rather than asset sale), to avoid certain transfer duties, or to organize succession.
The Seychellois themselves highlight the benefits of an offshore holding company for:
A single entity can hold properties in several countries. Resale is done by transferring the company’s shares rather than the property, thus limiting transfer costs. It also protects the asset from local succession or tax rules (inheritance tax, capital gains taxation). Finally, it centralizes the management of international investments, supported by double taxation avoidance agreements, for example with Indonesia, Singapore, South Africa, Jersey, or Kuwait.
However, for a French tax resident, the use of a Seychellois structure immediately raises the issue of French anti-abuse rules: anti-holding devices in non-cooperative territories, articles on controlled foreign companies (CFC rules), regime for companies with predominantly real estate assets, obligation to declare accounts, capitalization contracts, or foreign trusts, etc. France closely scrutinizes any structuring aimed at artificially locating assets or income in jurisdictions where taxation is virtually non-existent.
If a Seychellois IBC owns real estate in Seychelles and its ultimate shareholder is a French tax resident, the income and capital gains may be considered transparent by France. The absence of local tax in Seychelles does not protect the French shareholder from French taxation on distributed income or capital gains from the sale of shares.
This type of arrangement must therefore be handled with extreme caution. It may be of interest from a Seychellois local law perspective (simplification of certain operations, absence of local inheritance tax, neutrality on capital gains) but does not offer “invisibility” vis-à-vis the French tax authorities (Bercy). French reporting obligations and tax regimes apply, sometimes with penalties if the jurisdiction concerned is non-cooperative.
Tax residence, extended stays, and articulation with France
The Seychelles recognizes tax residence for any person present at least 183 days per year in the country, or having a permanent home or center of vital interests there. The Seychellois personal income tax scale is progressive, with for citizens a 0% bracket up to about SCR 8,555.5 per month, then rates of 15%, 20%, and 30% above. Non-citizens do not benefit from the 0% bracket and are taxed from the first SCR earned on the same brackets.
For certain profiles (entrepreneurs, international freelancers, holders of significant movable wealth), becoming a Seychelles tax resident may seem attractive: only Seychellois-source income is taxable, with foreign-source income potentially 100% exempt locally. However, for French people, changing tax residence is governed by precise rules, notably the need to genuinely and durably transfer one’s center of interests outside France, at the risk of still being considered a French tax resident despite physical presence abroad.
Owning real estate in Seychelles and staying there regularly is not sufficient in itself to establish Seychellois tax residence under French criteria if significant ties remain in France (family, professional activities, center of wealth management, etc.). And even when Seychellois tax residence is clearly established, specific French rules may continue to apply (French taxation on certain French-source income, wealth tax (IFI) on properties located in France, etc.).
Real estate in Seychelles can be part of a broader international mobility strategy, but it does not constitute a “tax magic wand” to automatically escape French tax.
Expert in wealth strategy
What a French investor should remember
For a French person considering acquiring a property in the Seychelles, the main takeaways are as follows.
The Seychelles framework is undeniably attractive: territorial system, absence of inheritance tax and specific capital gains tax, moderate taxation of rents (15%), annual tax on foreign properties at 0.50% of value, no wealth tax, possibility to invest via companies benefiting from exemptions on foreign-source income. But this favorable framework does not erase French taxation.
The absence of a tax treaty between France and the Seychelles implies that:
A French tax resident is taxed in France on all income (rents, capital gains) derived from a property located in Seychelles, according to ordinary rules, without an automatic tax credit. Moreover, these assets fall within the scope of French inheritance tax if the heir has resided in France for six years out of the last ten.
Entry costs are not negligible: stamp duty at 5%, sanction duty of at least 1.5% (sometimes 12% for certain residential purchases), registration and deed fees, not to mention lawyer and notary costs to navigate the Immovable Property (Transfer Restriction) Act and the Immovable Property Tax Act.
A property in Seychelles can serve as a second home, a rental investment, a currency diversification asset, an element of international mobility, or a base for a foreign holding company. However, each use must be evaluated under both Seychellois local law and French tax law, as France taxes the entirety of its residents’ worldwide income and wealth.
In this context, real estate taxation in Seychelles is less a “tax shelter” tool for a French person than a relatively benign local environment onto which French taxation is superimposed, often more heavily. The final trade-off therefore depends as much on the intrinsic quality of the real estate project (location, profitability, appreciation prospects) as on its compatibility with the taxpayer’s personal situation and long-term objectives.
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Cyril Jarnias is an independent expert in international wealth management with over 20 years of experience. As an expatriate himself, he is dedicated to helping individuals and business leaders build, protect, and pass on their wealth with complete peace of mind.
On his website, cyriljarnias.com, he shares his expertise on international real estate, offshore company formation, and expatriation.
Thanks to his expertise, he offers sound advice to optimize his clients' wealth management. Cyril Jarnias is also recognized for his appearances in many prestigious media outlets such as BFM Business, les Français de l’étranger, Le Figaro, Les Echos, and Mieux vivre votre argent, where he shares his knowledge and know-how in wealth management.
