Eswatini taxes income derived from or deemed to be sourced within the country, applying a broadly territorial approach regardless of the recipient's actual residence. The system is administered by the Eswatini Revenue Authority (ERA), with the standard corporate income tax rate reduced from 27.5% to 25% for company year-ends after December 31, 2024.
The tax year generally follows the company's own financial year-end, which may differ from the calendar year; individuals are assessed on the calendar tax year.
Eswatini's corporate income tax (CIT) rate is 25%, effective for financial year-ends after December 31, 2024 (down from a prior 27.5%), per PwC's Eswatini tax summary - given the current date, all current-year assessments now fall under this 25% rate. This specific rate change was part of a broader package of reforms generally effective July 1, 2024.
The headline personal income tax (PIT) rate is 33%.
The standard VAT/GST (or equivalent consumption tax) rate is 15%.
Eswatini's tax law does not specifically define residence for individuals; in practice, anyone employed or in business in Eswatini is regarded as resident for tax purposes, including expatriates working under an employer's permit or self-employed individuals. Corporate PE is determined by physical presence. Eswatini has no separate capital gains tax.
Eswatini's definition of permanent establishment was broadened in recent reforms to include consulting services provided by a person present in Eswatini for more than 30 days in a 12-month period, a notably low threshold compared to the more common 183-day or fixed-place-of-business standards; Eswatini's tax treaty with South Africa raises this to a 90-day threshold for South African residents, illustrating how treaty relief can meaningfully narrow the domestic-law PE trigger. A branch of a foreign company remains taxable on its Eswatini profits at the standard corporate rate, with a 15% additional tax on after-tax profits repatriated to the head office.
Eswatini has no CFC legislation of any kind.
Eswatini has no thin capitalization rules and no transfer pricing legislation, though the Eswatini Revenue Authority can invoke general anti-avoidance provisions to scrutinize related-party transactions for arm's-length pricing.
Eswatini classifies entities under its own domestic tax law rather than offering an elective check-the-box system, and no ATAD2-style anti-hybrid mismatch regime addressing double-deduction or deduction-without-inclusion outcomes has been identified, consistent with Eswatini having no CFC legislation of any kind and no transfer pricing legislation beyond general anti-avoidance provisions.
No domestic FBAR-equivalent regime requires Eswatini residents to separately disclose foreign financial accounts, and Eswatini is not currently a CRS participating jurisdiction, so it does not automatically exchange financial account information with foreign tax authorities under the OECD's Common Reporting Standard. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of Eswatini's own rules.
No dedicated participation exemption regime for dividends or capital gains from a qualifying subsidiary was identified in Eswatini tax law; Eswatini has no separate capital gains tax, and business-asset gains (including shares) are instead included directly in ordinary taxable income under the corporate rate.
Eswatini does not have a foreign tax credit regime. Relief from double taxation for Eswatini residents with foreign-source income therefore depends entirely on Eswatini's limited network of roughly 6 double tax treaties (including a long-standing 1968 treaty with the UK) rather than a standalone unilateral credit mechanism.
Eswatini maintains approximately 6 double tax treaties, including a long-standing UK treaty (signed and effective 1968).