25% standard rate.
Top marginal rate 30%.
15% standard rate.
Confirmed directly via Sections 5 and 6 of the primary Income Tax Order 1993. An individual is a resident for the full year of assessment if they (a) have a normal place of abode in Lesotho and are present in Lesotho for part of the year, or (b) are present in Lesotho for more than 182 days in any consecutive 12-month period that includes all or part of the year of assessment, or (c) are a Lesotho Government official posted overseas during the year, or (d) are otherwise a resident of Lesotho. A company is a resident company if it (a) is incorporated or formed under the laws of Lesotho, or (b) has its management and control in Lesotho, or (c) undertakes the majority of its operations in Lesotho; a Lesotho branch of a non-resident company is itself treated as a separate resident-company person. Resident taxpayers are taxed on worldwide income (gross income "from all geographical sources" per Section 17(2)); non-residents are taxed only on Lesotho-source income. Capital gains on disposal of immovable property or marketable securities are included in assessable income under the Order's general gains-and-losses-on-disposal rules (Sections 59-63). Lesotho applies transfer pricing and general anti-avoidance provisions under Part XI of the Order (Sections 113-114) to transactions between associated persons.
Confirmed directly via the full primary text of the Income Tax Order 1993 (Lesotho's governing income tax statute, reviewed in full this session via Lesotho's official legal database, LesLII): Lesotho does not have a classic Controlled Foreign Company regime of the kind that automatically attributes a controlled foreign entity's undistributed profits to a resident shareholder each year based on an ownership-percentage threshold. Instead, Section 106 of the Order ("Tax Havens") gives the Commissioner discretionary power to adjust a resident's income and foreign tax credit position where the resident has entered into a transaction that directly or indirectly results in foreign-source income being derived through a non-resident company connected to a tax haven. A foreign country may be treated as a tax haven under this section where it has effective tax rates significantly lower than Lesotho's, or laws providing for the secrecy of financial or corporate information that facilitate concealment of an asset's real owner - but the Commissioner will not treat a country as a tax haven under this section if Lesotho has a double taxation agreement with it. This is a transaction-specific, discretionary anti-avoidance mechanism, not an automatic, ownership-threshold-based attribution regime - a real, meaningful structural distinction from countries with conventional CFC rules (such as South Africa's Section 9D, reviewed separately on this site).
Confirmed directly via Section 36 of the primary Income Tax Order 1993: where a resident company not principally engaged in a money-lending business has a debt-to-equity ratio in excess of 3 to 1, the Commissioner may disallow a deduction for the interest paid on the portion of the debt exceeding that 3:1 ratio. This is a specific, statutory, primary-sourced rule - not a general anti-avoidance provision applied at the Commissioner's broader discretion, but a defined numeric threshold set out directly in the governing tax statute.
Lesotho has no domestic equivalent to the US FBAR/Form 8938 regime - the Income Tax Order 1993 contains no provision requiring Lesotho residents to self-report foreign bank accounts to Revenue Services Lesotho, consistent with Lesotho's residence-based (not citizenship-based) tax system. Separately and independently of Lesotho law, US citizens and Green Card holders with Lesotho accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of Lesotho's own requirements.
Lesotho has concluded double tax treaties with Botswana, Eswatini, Mauritius, and South Africa, per a 2025 practitioner guide. RESOLVED: the UK-Lesotho Double Taxation Convention (signed January 29, 1997, entered into force December 23, 1997) is NOT currently in force - the UK Government's own official archived copy of the treaty is filed and titled explicitly as "terminated" (gov.uk/HMRC document repository), the most authoritative and primary source available on this specific question. This directly overrides a 2025 secondary practitioner guide that lists the UK as a current treaty partner - that listing is incorrect and is not relied upon here. Confirmed via Section 112 of the primary Income Tax Order 1993: where the terms of a treaty are inconsistent with the Order, the treaty terms prevail - meaning for any Lesotho treaty genuinely in force, the treaty text controls over the general Order provisions.