Corporate - Corporate residence

Last reviewed - 02 January 2024

A company is tax resident if it is incorporated or formed under the laws of Tanzania or if the management and control of its affairs is exercised in Tanzania, whether physically or through any electronic means.

Permanent establishment (PE)

A non-resident entity has a PE in Tanzania if it carries on business in Tanzania. This includes a place where a person:

  • is carrying on business through an agent, other than a general agent of independent status acting in the ordinary course of business as such, provided that, where an agent other than an independent agent is acting on behalf of another person, that other person shall be deemed to have a PE if:
    • the agent, other than an independent agent, has and habitually exercises authority to conclude contracts or issue invoices on behalf of that other person, unless their activities are limited to the purchase of goods or merchandise for that other person
    • the agent, other than an independent agent, has no authority to conclude contracts but habitually maintains stock of goods or merchandise from which they regularly deliver goods or merchandise on behalf of that other person, or
    • the agent, other than an independent agent, habitually secures orders, wholly or almost wholly for that other person or for the enterprise and other enterprises controlling, controlled by, or subject to the same common control, as that of that other person
  • has used or installed, or is using or installing, substantial equipment or machinery, and
  • is engaged in a construction, assembly, or installation project for six months or more, including a place where a person is conducting supervisory activities in relation to such a project.