Sierra Leone taxes residents on worldwide income and non-residents on Sierra Leone-source income only, under the Income Tax Act 2000 (as amended) - a common-law framework reflecting Sierra Leone's history as a British colony, not the French-derived Code General des Impots structure used across Francophone West Africa. Sierra Leone operates a self-assessment system for corporate tax, administered by the National Revenue Authority (NRA).
Sierra Leone's tax year is the calendar year.
30% standard rate (raised from 25% around 2025/2026).
Top marginal rate 30% (raised from 15% around 2025/2026).
15% standard GST.
An individual is resident under the more-than-182-day test (satisfied by a single period of presence, or by aggregating two or more periods within a 12-month window; partial-day presence counts as a full day). Officials of the Sierra Leone government posted overseas remain resident individuals. Diplomats and their dependents are treated as non-resident for tax purposes, meaning their non-Sierra Leone income is excluded from Sierra Leone taxation, though Sierra Leone-source investment income they derive remains taxable. A company is resident under Section 12 of the governing statute if it satisfies any of three alternative tests: place of incorporation, place of management and control, or place of majority of operations; a branch of a non-resident company is deemed a separate resident-company person.
A non-Sierra Leone-resident entity has a Sierra Leone permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Sierra Leone on the entity's behalf, following the OECD Model Treaty definition as applied under Sierra Leone's domestic law and any applicable tax treaty.
No CFC-style attribution provision exists in Sierra Leone's Income Tax Act 2000. Sierra Leone's related-party framework evolved from a 2016 Finance Act amendment (Section 95) requiring related-party transaction disclosure (relationship, transaction value, pricing basis, and comparable pricing) without formal transfer pricing regulations, to a 2021 Finance Act amendment (Section 89) that formally empowers the Minister of Finance to issue transfer pricing regulations administered by the Commissioner General, applying an arm's-length recharacterization standard to related-party transactions. Outside this framework, the Commissioner General retains a general power to recharacterize or disregard any transaction entered into as part of a tax avoidance scheme. This is a transfer-pricing and general anti-avoidance framework, not a CFC regime attributing a foreign subsidiary's own undistributed profits to a Sierra Leone parent.
No statutory thin capitalization ratio is identified in available sources.
Sierra Leone does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics under Sierra Leone's own common-law legal tradition. Sierra Leone does not have a comprehensive ATAD2-style anti-hybrid regime.
No foreign bank account or foreign financial asset reporting regime exists requiring residents to separately disclose foreign accounts; foreign income is reported through the standard annual tax return.
Sierra Leone does not provide a broad participation exemption for foreign dividends in the European sense, consistent with the transfer-pricing-focused (rather than exemption-focused) anti-avoidance framework already confirmed elsewhere on this page; relief from double taxation is available primarily through Sierra Leone's foreign tax credit system where one exists.
Sierra Leone has a foreign tax credit mechanism for foreign tax paid on foreign-source income also taxed domestically, capped at the domestic tax otherwise due on that income - confirm current specific provisions directly given limited public documentation of this area for Sierra Leone.
Sierra Leone has a Double Taxation Arrangement with the United Kingdom, originally signed December 19, 1947 and given force in UK law via the Double Taxation Relief (Taxes on Income) (Sierra Leone) Order 1968, confirmed as still current via the UK government's official tax treaties listing. Sierra Leone also signed a treaty with the United Arab Emirates (signed December 24, 2019). Sierra Leone has no bilateral income tax treaty with the United States, confirmed via the US State Department's own Investment Climate Statement. Sierra Leone is in the process of developing a model tax treaty consistent with the African Tax Administration Forum (ATAF) framework. A comprehensive list of any further bilateral partners is not compiled in available sources for this page.