Investment & TISEZA

Investment and Special Economic Zones Act 2025: What the Statute Actually Changed

By CFE. Joseph Magweiga Marwa · Reviewed by Advocate Yona Habiye · Published 2026-09-10 · Last reviewed 2026-09-10 · 20 min read

This page is the statutory operating file: what the gazetted Act says, what it repealed, and which sentences still have to survive TRA. It is not a how-to for investor registration, not a TIC-certificate filing note, and not the downloadable practitioner book. Those sit on sister pages so the files do not repeat each other.

• Registration scope and limits — TISEZA investor registration
• Old TIC certificate language — TIC certificate now filed under TISEZA
• Fee families in the 2025 schedule — TISEZA fees and payments 2026
• Who may represent you at the one-stop — ISP guideline
• The 2026 practitioner book — Complete Guide to TISEZA download card

Law is stated as at 10 September 2026. The English version used here is the Attorney-General translation published through Government Notice No. 4 of 2026 as the Investment and Special Economic Zones Authority Act, Cap. 38. The commonly cited short name remains Act No. 6 of 2025. Where the Swahili principal text and this English version could diverge, the gazetted principal wins. Confirm live on tiseza.go.tz and the Attorney-General e-library before you cite a section in a filing.

What three statutes disappeared — and what stayed valid

Section 51(1) of the English text repeals, by name, the Tanzania Investment Act of 2022, the Export Processing Zones Act of 2002 and the Special Economic Zones Act of 2006. That is the whole institutional change in one sentence. TIC and EPZA are not “rebranded desks.” Their founding Acts are gone.

Section 51(2) then does the work most blogs skip. A certificate of incentives or a licence issued under a repealed Act remains valid on its own terms until the period of the benefit expires. An agreement entered under a repealed Act does the same. Only after that expiry do the new Act’s terms bite that file. Pending TIC or EPZA matters are deemed pending before TISEZA. Pre-commencement regulations for zones remain in force until they are replaced.

The practical read is uncomfortable and useful. An investor holding a 2023 TIC certificate is not automatically on the 2025 incentive list. They are on the list that was written into their paper, for the years that paper still runs. Modelling a 2025 zone holiday onto a 2022 TIC certificate is a category error.

Section 15 is a commencement rule, not an incentive

Section 15(1) says every investor intending to make any investment in Tanzania shall be registered with the Authority before commencing investment activities. Procedure is left to the regulations. After registration, the investor must still comply with the conditions that govern the intended activity.

That last clause is the one that stops a TISEZA printout from being treated as a mining right, a CRB class, a TMDA product registration or a cashew buying licence. TISEZA registration is a facilitation identity. The sector mandate-holder still owns the operating instrument. The thin registration page already says this. The statute is why it is true.

Zanzibar is outside this file. The Act is a Mainland investment-and-zones statute. ZIPA, BPRA and ZRA are a different jurisdiction. The ZIPA orientation sits on Investing through ZIPA.

Certificate outside a zone, licence inside one

Section 16 is the split that older “TIC certificate” copy flattens. An investor may apply for:

• a certificate of investment for activities outside a special economic zone; or
• an investment licence for activities inside a special economic zone.

Either instrument may be issued for a new investment, a rehabilitation or an expansion. Qualifications sit in the regulations, not in the Act’s own schedule. Section 17 then makes the paper non-transferable without TISEZA approval, and lists revocation grounds that include fraud, unapproved transfer, failure to commence within twelve months without valid reason, and failure to submit implementation reports for twenty-four consecutive months.

Section 18 requires written notice if the investment ceases, if another person succeeds to it, if the name or particulars change, or if the project expands. A successor who is not told this will discover it when a later incentive claim is refused because the register still names the old vehicle.

This is why the existing TIC-certificate page keeps four concepts separate: registration, Certificate of Incentives eligibility, SEZ/EPZ arrangements, and ordinary BRELA/TRA setup. The Act’s own vocabulary is certificate-versus-licence, not “TIC paper versus EPZA paper.”

Section 19 names incentives — then hands them to the tax Acts

Section 19(1) is the sentence the practitioner book was built around. An investor holding a certificate may receive tax and non-tax incentives provided under the Income Tax Act, the Excise (Management and Tariff) Act, the Value Added Tax Act, or any other applicable law at the time. The investment Act does not create those reliefs. It points at the statutes that do.

Section 19(2) then lists, for a licence in a special economic zone, a longer menu: duty and VAT relief on raw materials and capital goods; a ten-year corporate-income-tax exemption; ten-year withholding-tax exemptions on rent, dividends and interest; withholding-tax exemption on foreign-loan interest; ten-year local-government levy relief on zone goods; limited vehicle and bus relief; a short business-visa mention; transit-style treatment of goods entering a zone; VAT relief on utilities; a port-charge exemption; stamp-duty relief on zone property documents; and VAT relief on construction materials and services.

Section 19(4) closes the door the list just opened: those incentives “shall be granted in accordance with the conditions and procedures specified in the laws governing the incentives.” The 2026 Complete Guide to TISEZA — law stated as at 25 August 2026 — applied that test and marked the withholding-tax holidays as not yet accessible, because they were not mirrored in the Income Tax Act at that date. Finance Act 2025 is separately reported as restricting the ten-year corporate-tax holiday to exporting investors. This page does not upgrade either finding. Confirm the live Income Tax Act and VAT Act before a model treats s.19(2) as cash.

Section 20 requires TISEZA to publish a list of incentives available under various laws in the Gazette. If that list and the tax Act disagree, the tax Act still wins. Section 19(4) already said so.

Strategic-investor status is a Cabinet file, not a portal tick

Section 21 sets the published capital floors for strategic-investor status: the Tanzanian-shilling equivalent of USD 20 million for a domestic investor and USD 50 million for a foreign investor, plus other criteria left to the regulations. Additional incentives are recommended by the National Investment Development Committee and submitted by the Minister to Cabinet. That is not a one-stop upload. It is a political-economy file sitting on top of an already-registered project.

The fee for applying for that status is a separate instrument. The Second Schedule printed with GN No. 466 puts the strategic-investor application at TZS 60,000,000. That figure is oriented on the fees page and must be confirmed live. It is not a Zatra charge.

Zones, customs and service providers inside the fence

Part IV (sections 25–30) is the SEZ machinery: establishment, customs treatment, import and delivery of goods and services, zone management, and — at section 30 — service providers in a special economic zone. That last section is not the same instrument as the Investor’s Service Provider guideline that registers consultants to walk a file through the one-stop. The ISP operating file sits on its own page. Do not collapse “zone contractor” and “registered ISP” into one sentence.

Customs treatment of a zone as sitting outside the ordinary domestic customs territory is a TRA administration problem. The Complete Guide walks Form C.17 and the security bond. This page only needs the statutory point: goods that leave a zone for the Mainland are not “already Tanzanian.” They re-enter.

Guarantees, immigrant quota and what the Act does not do

Part V restates transfer of capital, profits and dividends through authorised channels, a guarantee against nationalisation or expropriation except for a public purpose with compensation, equal opportunity for a foreign investor, an immigrant quota, and access to domestic credit. Those are investment-law sentences. They do not waive Bank of Tanzania procedure, withholding tax on a remittance, or Labour/Immigration classes for the people who will actually work.

Section 36’s immigrant quota is not a work permit. Work and residence permits remain a Labour and Immigration file. GN No. 487A of 2025 is separately reported as reserving scheduled business activities to citizens. This page publishes no penalty figure for that Order. Whether it reaches companies is an open question requiring an advocate’s opinion against the gazetted text.

The information the 2026 book could not yet print

Zatra’s Complete Guide to TISEZA, 2026 edition, stated as at 25 August 2026 that its Tier-3 tray — gazetted text of the 2025 Act and Regulations — was empty. This page is the first Insights file written against the English version published as GN No. 4 of 2026. That is the information gain. It does not make the practitioner book wrong on TRA practice. It supplies the section numbers the book was careful not to invent.

What remains unopened here: the full 2025 Regulations text, including the 30-day decision clock and the general-scheme capital thresholds that circulate as about USD 500,000 foreign / USD 50,000 wholly Tanzanian-owned. Those figures appear in secondary commentary and in TISEZA orientation. They are not quoted from a section of the Act in hand. Confirm them on the live One-Stop portal before a structure is built around them.

Build sequence for a 2026 file

1. Decide whether the project is outside a zone (certificate track) or inside a gazetted SEZ/EPZ (licence track). That is section 16, not a branding preference.
2. Incorporate or register the vehicle at BRELA and open the TRA file. TISEZA does not replace either.
3. Register under section 15 before you commence. Use a registered ISP if the one-stop now requires one for submissions.
4. Apply for the certificate or the zone licence on the portal that matches the track. Do not file a zone licence on the general-scheme form.
5. Model incentives only where the relevant tax Act currently grants them. Park s.19(2) withholding-tax rows as pending until TRA’s statute says otherwise.
6. Keep the sector licence, land, EIA and people files on their own desks. Section 15(3) already told you to.

Professional fees for that sequence stay on Zatra’s pricing page, on their own line, separate from TISEZA schedule fees, TRA tax and bank costs. Approvals are not guaranteed.

EPZ, SEZ and the customs fence the Act actually builds

Casual copy treats “EPZ” and “SEZ” as two logos for the same park. The 2025 Act keeps them as one authority’s problem, but the operating difference is still customs, not branding. An export-processing operation is a bonded manufacturing circuit: plant, machinery, equipment and raw materials enter under a security bond, TRA tracks them through production, and they are supposed to leave as exports. A special economic zone is a gazetted geography that can host manufacturing, logistics, services and developer infrastructure — not export production alone. Both sit, in TRA practice, outside the ordinary East African customs territory. That is why goods that leave a zone for Mainland consumption are not “already Tanzanian.” They re-enter, and ordinary duty, VAT and documentation apply.

The Complete Guide to TISEZA, 2026 edition, walked the TRA EPZ documentation that still sits under that fence: Form C.17 on importation with a CB-form security bond; monthly stock records with a return by the 15th of the following month; a penalty of twice the duty payable on goods found missing; export cancellation of the bond only when seals check out; inter-zone movement on the same forms; plant sent for repair treated as a temporary importation on return; waste destroyed under customs supervision or sold domestically as an import. This page does not reprint TRA’s forms. It records that section 25–30 of the English Act is the statutory hook, and that TRA still administers the paper. Confirm the live EPZ customs page on tra.go.tz before a warehouse procedure is written.

Four parks TISEZA reported as opening in Q4 2025 — Bagamoyo Eco Maritime City, Kwala in Kibaha, Nala in Dodoma, Buzwagi in Kahama — are geography, not licences. The Eastern Zone file owns Dar–Pwani. Nala and Buzwagi are other zones. A photograph of sheds on bush is not a plot allocation.

What TRA will currently grant — and what the Act only names

The practitioner book’s useful table is the one that refuses to treat section 19(2) as a cashflow. Stated as at 25 August 2026, and still the working test on 10 September 2026:

Incentive named around the 2025 framework	Accessible on the book’s reading?	Why this page will not upgrade it
Ten-year corporate-income-tax exemption for a zone licensee	For qualifying exporters, not as a domestic-sales holiday	Finance Act 2025 is reported as excluding producers who sell into the domestic market. Income Tax Act practice is reported as a 100% export test; the investment Act’s own export bar is often cited at 80% outside the EAC. Those two tests are not identical. Confirm TRA on the facts.
Import-duty relief on capital goods and raw materials	Yes, in TRA/customs practice for qualifying files	Still a customs file, not a TISEZA printout.
VAT relief on production-related goods and services	Yes in principle; spare parts, motor vehicles and consumables are the usual exclusions	Those exclusions route to refund claims, not to an upfront stamp. Confirm the live VAT Act.
Withholding-tax holidays on rent, dividends, interest and foreign-loan interest	Not yet accessible on the book’s reading	Named in the investment legislation; not mirrored into the Income Tax Act at the book’s date. TRA cannot lawfully grant a relief the tax Act does not contain.
Ten-year local-government levy relief on zone goods	Yes in the book’s table	Confirm the live local-government instrument, not only the investment Act.
VAT on utilities; stamp duty; VAT on construction materials	Yes in principle, with documented invoice friction on utilities	Zero-VAT invoices are an administration problem. A model that assumes they arrive on day one is optimistic.
Business visa on arrival; full port-charge exemption	Unconfirmed in the book	This page does not convert an unconfirmed row into a promise.

The one insight worth keeping is mechanical: an incentive is cash only when the tax statute TRA administers contains it. Modelling a shareholder-loan on a ten-year withholding holiday because section 19(2) lists foreign interest is how a financing plan dies at the first TRA assessment. Park those rows as pending. Build the model on duty, VAT-on-production-inputs, local-levy relief and whatever corporate-tax holiday TRA will actually stamp for an exporter.

Registered investment is not realised FDI. TISEZA’s own 2025 full-year figures, as reported in contemporaneous coverage of the authority’s release, put about 915 projects and about USD 10.95 billion of registered value. Q1 2026 reporting cited about USD 1.14 billion across 182 projects and SEZ/EPZ export turnover of about USD 752.40 million, up sharply year-on-year from a low base. Those are TISEZA registration and zone-turnover figures, not Bank of Tanzania realised-FDI lines. Do not put them in a bank model as cash already in the country.

Where files actually stall

Five failure modes are documented in practice and in the statute, not invented as scare copy.

Commencing before section 15 registration. The English text requires registration before investment activities commence. A company that has already broken ground, hired, or imported plant and then files TISEZA as an afterthought is arguing about regularisation, not about a clean certificate. Procedure sits in the regulations. Confirm how the live one-stop is applying “commencing.”

Filing the wrong instrument. A general-scheme certificate on bfportal, or a zone licence on the general one-stop, is a category error under section 16. Coordinators will talk. The portal that matches the track still has to be the one that receives the file.

Treating a 2022 TIC certificate as a 2025 zone holiday. Section 51(2) keeps old paper valid on its own terms until the benefit period expires. It does not migrate that paper onto the new list.

Modelling withholding-tax holidays as cash. Covered above. The stall is at TRA, not at TISEZA.

Skipping BRELA, TRA, land or the sector board because “TISEZA is a one-stop.” Section 15(3) already said the investor must still comply with the conditions governing the activity. Mining, energy, construction, cashew, film and livestock each keep their mandate-holder. GN No. 487A of 2025 is separately reported as reserving scheduled activities to citizens. This page publishes no penalty figure. Get an advocate’s reading of the gazetted schedule before a foreign-owned vehicle assumes an activity is open.

The circulating 30-day decision clock and the general-scheme capital floors (about USD 500,000 foreign / USD 50,000 wholly Tanzanian-owned in secondary commentary) are regulation-and-portal figures. They are not quoted here from a section of the Act in hand. Confirm them on onestopshop.tiseza.go.tz before a structure is built around them.

Currency of this file

Tanzanian investment legislation is now a 2025 Act with a 2026 English translation and a fee schedule printed in July 2025. Regulations, portal forms and Finance Acts move independently. This page will need a restatement when a new Gazette replaces GN No. 466, when the Income Tax Act is amended to match s.19(2), or when TISEZA publishes the section-20 incentive list in a form that disagrees with current TRA practice.