South Sudan taxes resident companies on worldwide income under the Taxation Act 2009 (as amended, most recently by the Financial Act 2024/2025), administered by the South Sudan Revenue Authority (SSRA); non-resident companies are taxed only on South Sudan-source profits. The standard Business Profit Tax rate is 25%, with a separate fiscal regime for oil and mining companies.
The tax year generally follows South Sudan's fiscal year framework under the Taxation Act 2009; withholding tax payments (previously final for certain payment types) were changed under the Financial Act 2023/2024 to be treated as advance tax usable as a credit on the income tax return, with overpayments eligible for refund.
25% standard rate (separate fiscal regime for oil and mining companies); tax system still developing since 2011 independence.
Progressive, 0% to 20% on monthly income.
18% VAT (introduced but system still being fully implemented).
An individual is resident if they have their habitual abode in South Sudan. A company is resident if incorporated in South Sudan; resident companies pay tax on worldwide income, while a non-resident company pays tax only on South Sudan-source profits. There are no exchange controls, though significant foreign exchange transactions must be reported to the central bank.
A non-resident company operating through a permanent establishment in South Sudan is taxed on South Sudan-source profits attributable to that establishment; even without a PE, employing staff locally in South Sudan creates payroll and income tax withholding obligations. A final withholding tax of 10% on gross payments (dividends, interest, royalties) applies regardless of whether the recipient is resident or non-resident.
No CFC-style attribution provision was found in South Sudan's tax legislation. South Sudan's tax system is governed by the Taxation Act 2009 (as amended, most recently by the Financial Act 2024/2025). Multiple specialist sources covering South Sudan's tax system in detail (Addleshaw Goddard, EY, KPMG) - which would be expected to flag a CFC regime if one existed, given their comprehensive coverage of the country's business-profit tax, withholding tax, and other business-relevant provisions - make no mention of one.
No statutory thin capitalization ratio is identified in available sources.
South Sudan classifies entities under its own domestic Taxation Act 2009 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 no CFC-style attribution provision being found in South Sudan's tax legislation despite genuine search effort, including checks of specialist sources (Addleshaw Goddard, EY, KPMG) covering the country's business-profit tax framework in detail without mentioning one.
No domestic FBAR-equivalent regime requires South Sudan residents to separately disclose foreign financial accounts, and South Sudan 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 South Sudan's own rules.
A dedicated participation exemption regime for dividends or capital gains from a qualifying subsidiary distinct from the general 10% final withholding tax on dividends described elsewhere on this page is not confirmed in available primary sources; confirm current treatment directly with the South Sudan Revenue Authority before relying on this page.
Section 91 (Credit for Tax Paid) of the Taxation Act 2009 provides that a South Sudan resident who makes a profit from outside South Sudan and pays tax on that profit abroad will be allowed a foreign tax credit if a tax treaty applies or the other country provides a similar foreign tax credit; a foreign tax credit is also confirmed as a standard incentive granted to any resident company paying foreign taxes on income from business activities outside South Sudan, per South Sudan's Investment Promotion Act framework.
Sources genuinely conflict here, and the more specific claim is preferred: TaxAtlas states South Sudan has not yet established any double taxation agreements, while BRITACOM (the Belt and Road Initiative Tax Administration Cooperation Mechanism, of which South Sudan is a Council member) specifically names signed tax treaties with Morocco and the United Arab Emirates. Given BRITACOM's claim is specific and named rather than a blanket assertion, it is treated as the more reliable indicator that South Sudan's treaty network - while still very much in an early, expanding stage consistent with the country's young tax administration - is not literally zero. No US tax treaty exists.