The Seychelles Company [Special License] (CSL)

The Companies Special License (CSL) is regulated by the “Companies (Special Licenses) Act, 2003”
(the “Act”). The CSL entity is a Seychelles domestic company (formed under the Companies Act,
1972) to which a special license is granted under the Act by the Financial Services
Authority (“FSA”).

•Key features of the CSL are as follows:

•Minimum of two shareholders are required. Corporate and individual shareholders allowed;

•Bearer shares are not permitted;

•Minimum of two directors who cannot be corporate entities.

•A Director need not be a resident of Seychelles

•The company secretary must be a resident of Seychelles

•Requirement to file audited accounts annually

•Continuation or redomiciliation as a CSL is allowed;

•CSL can be continued in another jurisdiction;

A CSL has substantial statutory tax advantages including access to the Seychelles Double Taxation
Agreements (DTA). The Seychelles has a number of DTAs with several countries. More treaties are
currently being negotiated.

The CSL also benefits from the following additional tax advantages:

•Liable to Seychelles business tax at the rate of 1.5% on its world-wide income (as an exception to the   Seychelles territorial tax system, any foreign income derived by a CSL will be deemed to be   Seychelles-sourced income);

•Exemption from withholding taxes on dividends, interest and royalties;

•Exemption from stamp duty on property transfers, share transfers and other business transactions;

•Exemption from trades’ tax on all furniture and equipment imported into Seychelles for office use;

•Exemption from work permit fees for expatriate workers;

Please note that information relating to the beneficial ownership of the company will not be submitted to FSA. This information is kept confidential with ACM as per section 22 of the Act. Once the Registrar of Domestic Companies has issued the certificate of incorporation, FSA will thereafter issue a Special License under section 9(1) of the Act. The process for the incorporation of a CSL may take approximately a minimum of 4 to 6 weeks upon receipt of all documentation and fees from the client.

The above facts are given for purposes of general information only and any further details may be obtained by contacting ACM directly or by referring to the Act