Eswatini

New tax legislation has been introduced effective 1 July 2024.

The corporate tax rate has decreased from 27.5% to 25%.

A presumptive tax has been implemented where the turnover is 500,000 Eswatini lilangeni (SZL) and less.

Withholding taxes (WHTs) on non-residents has been fixed at 15%. There had previously been dispensation of 12.5% for certain countries.

Allowance for the construction of a farmhouse has increased from SZL 60,000 to SZL 100,000.

Initial allowance has been changed from 50% to 30% on expenditure of SZL 5 million and more.

There will be gains and losses on the disposal of business assets.

Ring-fencing of losses has been introduced. This is applicable to business income of an individual, property income of an individual, manufacturing income of a resident company, and farming income of an individual.

Losses carried forward will be limited to five years. Timber and orchard plantations are not impacted. 

The commissioner can deem shareholder loans to be taxable where such amounts have not been repaid.

Transfer pricing rules have been introduced (arm’s-length determination, transfer pricing methods, and the tested party).