Taxes in Sierra Leone

The National Revenue Authority (NRA) administers domestic taxes through its Domestic Tax Department (DTD), including the Large Taxpayers Office, Extractive Revenue Industries Unit and Small and Medium Taxpayers Office. The Customs Service Department handles customs duties and import procedures. The main legal framework includes the Income Tax Act 2000, Goods and Services Tax Act 2009, Revenue Administration Act 2017, Customs Act 2011, Pay-Roll Tax Act 1972, Excise Act 1982, Tax and Duty Exemptions Act 2023 and the applicable Finance Acts. A Taxpayer Identification Number (TIN) is required for individuals, self-employed people, companies, partnerships, NGOs, importers, exporters, public bodies and exempt bodies. An applicant generally uses a National Identification Number or business registration details through the Integrated Tax Administration System (ITAS). The NRA states that routine TIN processing can take about 24 hours. A TIN does not by itself determine the amount of tax due; the liability depends on the taxpayer's activity, income, status and transactions. The tax year normally runs from 1 January to 31 December. A substituted accounting year requires approval from the Commissioner-General. An individual is generally resident when present in Sierra Leone for at least 182 days in any 12-month period, and Sierra Leone citizens or government employees abroad can also fall within the resident rules. A company is resident when incorporated under the Companies Act 2009 or managed and controlled in Sierra Leone. Residents generally report worldwide income, while non-residents are generally taxed on Sierra Leone-source income. A permanent establishment is treated as a resident company for the relevant income-tax rules. Employment income includes salary and taxable fringe benefits. Resident individuals are subject to progressive personal income tax with a maximum marginal rate of 30%. The NRA's current table applies 0% to monthly income up to NLe300,000, 15% to the next NLe300,000, 20% to the next NLe300,000 and 30% above NLe900,000 per month. An older NRA guide uses different bands, so employers and individuals should confirm the current ITAS or NRA table before filing. Employers generally deduct Pay As You Earn (PAYE) and remit it with the required return. Non-resident individuals are generally subject to a 25% rate. The National Social Security and Insurance Trust (NASSIT) contribution is separate from income tax. The employee contribution is 5% and the employer contribution is 10% of basic salary, making a combined 15%; the employee share is deductible under the stated rules. Payroll tax can also apply to employers of foreign employees, with the general payment date stated as 31 January and an additional annual return requirement under Finance Act 2025. Resident and non-resident companies generally pay corporate income tax at 30% of taxable income. Finance Act 2026 introduced or confirms a minimum tax based on the higher of corporate income tax on chargeable income or 2% of turnover. Investment allowance has been removed. Companies generally pay four equal instalments by the 15th day of the third, sixth, ninth and twelfth months, and the annual corporate income tax return is generally due by 30 April. Allowable income-generating expenses, capital allowances and losses carried forward for up to 10 years can affect taxable income. Related-party transactions may require disclosures and local-file, master-file and country-by-country reporting; the stated penalty for a breach is 3% of the transaction value. Some individual and partnership businesses may use a turnover-based small or micro-business regime. The stated bands are 0% below NLe10 million turnover; NLe100,000 plus 2% between NLe10 million and NLe20 million; NLe300,000 plus 4% between NLe20 million and NLe100 million; NLe3.5 million plus 5% between NLe100 million and NLe200 million; and NLe8.5 million plus 6% between NLe200 million and NLe350 million. This regime excludes property owners, employees and companies. A written election for the net-income method may be available with an annual return. The taxpayer classes used under Finance Act 2025 are micro up to NLe10,000, small above NLe10,000 to NLe500,000, medium above NLe500,000 to NLe6 million and large above NLe6 million, but the relationship between these classes and the older turnover regime should be confirmed with the NRA. Goods and Services Tax (GST) normally has a standard rate of 15%. A registered business calculates output GST, claims eligible input GST and pays the difference. Supplies may be standard-rated, zero-rated, exempt or outside the GST scope. The registration threshold is reported inconsistently as NLe350 million on some NRA material and NLe500,000 in an extract of a Finance Act 2024 document, so the current law and NRA confirmation should be checked before registration or filing. A GST return with input and output schedules is generally due 21 days after the tax period. GST-registered businesses must use electronic cash registers where required, and some professional services may require direct GST payment to the NRA. Withholding tax (WHT) rates depend on the payment and recipient. Finance Act 2026 lists 20% for specified contractors, dividends, interest and management or professional fees, and 15% for rent under the relevant schedules. Older NRA tables show different rates, including 5%, 10%, 15% and 25%, so the statutory payment category and recipient residence must be checked for each transaction. WHT and PAYE are generally due within 15 days after the relevant month. Rent tax can apply to income from Sierra Leone property regardless of the landlord's residence, and rental business chargeable income can be taxed at up to 30%. Capital gains tax is generally 30% of the gain, with the return and payment due at least 30 days after disposal. Importers and exporters need a TIN and use ASYCUDA, the electronic customs platform. The process normally includes an electronic declaration, assessment notice, bank payment, receipt and customs release. Customs duty is based on the Harmonized System tariff and may be 0%, 5%, 10%, 15%, 20% or 30% of CIF value. Imports can also attract 15% import GST, excise on products such as petroleum, tobacco, alcohol, sugary drinks and luxury vehicles, 5% import WHT on CIF value and a 0.5% ECOWAS levy on imports from outside ECOWAS. Returns and payments normally follow the applicable tax type. General annual income returns may be due 90 or 120 days after the assessment year depending on the applicable rule, while corporate income tax returns are specifically due on 30 April. The taxpayer submits the return, obtains an NRA paying-in slip and pays through a designated bank. Amounts above NLe50 million are paid through a bank or SWIFT. Tax records should generally be kept for at least six years. A Tax Clearance Certificate (TCC) confirms tax compliance for purposes defined by the applicable rules. Finance Act 2026 states a fee of NLe100; older NRA material refers to processing in about 72 hours, while ITAS automation has operated since 2025. Late filing and late payment can produce fixed penalties and percentage surcharges. For example, WHT or PAYE arrears can attract 10%, 15%, 20% or 25% according to the delay period. Finance Act 2025 lists annual income late-filing penalties of NLe25,000, NLe12,500 and NLe1,250 for large, medium and small taxpayers, with higher non-filer amounts of NLe50,000, NLe25,000 and NLe2,500. GST late-filing penalties are listed as NLe5,000, NLe2,500 and NLe500, with non-filer amounts of NLe10,000, NLe5,000 and NLe1,000 by taxpayer size. The NRA can issue notices, make default or adjusted assessments, request information, close a business, seize or auction assets, recover from third parties and restrict travel, port access or TCC issuance under the applicable enforcement rules. Taxpayers have rights to information, representation and objection. If an objection decision is not issued within 60 days, the objection may be treated as allowed under the stated rule. An appeal can generally go to the Revenue Review Tribunal within 30 working days and then to the High Court. GST matters may follow the Board of Appellate Commissioners process, with a High Court appeal generally due within 60 days. International agreements and tax treaties generally take priority over conflicting domestic rules unless anti-avoidance provisions apply. A foreign tax credit may be available for each income source, limited to the average Sierra Leone tax rate. Transfer pricing follows the arm's-length principle under the 2021 regulations. Extractive businesses may also need to consider the National Minerals Agency and the NRA, including the stated iron-ore safe-harbour rules. Tax treatment should therefore be checked against the current Finance Act, statutory schedule, NRA notice or ITAS instruction whenever rates, thresholds, deadlines or taxpayer status are uncertain.