Mainland vs Zanzibar Company Setup: Two Registrars, Two Tax Files

This page is the Union-split operating file for legal persons: which registrar, which tax desk, which investment authority, and which permit file you are actually in. It is not a BRELA click-through, not a BPRA fee table, and not a ZIPA incentive brochure.

• Zanzibar incorporation only: BPRA, not BRELA
• ZIPA vs TISEZA: ZIPA orientation
• Land split: Mainland vs Zanzibar land
• Work and residence in Zanzibar: Zanzibar permit guide

As at 10 September 2026. The United Republic is one state for Union matters and two legal landscapes for company law, many taxes, land and labour. Mixing the stacks is the usual stall.

Two registrars

That table is orientation. It is not a constitutional treatise. Confirm the live registrar and the live tax desk for the premises you will occupy. A Mainland certificate hanging in a Stone Town office is a decoration.

BRELA will not register a Zanzibar company

BRELA administers Mainland business registration under the Companies Act framework that applies there. The ORS portal issues Mainland companies. If the registered office, the directors’ meeting place you will actually use, and the trading premises are in Zanzibar, that is a BPRA file. Paying BRELA first ‘to get started’ creates the wrong person.

Groups that need both markets usually need both legal persons, or a carefully read cross-border structure an advocate will own. The pruned ‘running a group on both sides’ stub stays pruned so this page can stay the decision file.

Tax is not a photocopy

Some taxes are Union matters administered through TRA. Some Zanzibar domestic taxes are not. VAT thresholds, rates and filing desks have been different in practitioner material and in Zanzibar’s own publications. This page does not reprint a rate. See the companion tax-split orientation when it is upgraded; until then, confirm TRA and the Zanzibar Revenue Board for the tax you actually owe. Inventing a single ‘Tanzania VAT number’ for a Zanzibar-only trader is how the first return is wrong.

TISEZA is not ZIPA

Mainland investment registration and zone licences sit with TISEZA under the 2025 Act. Zanzibar investment facilitation sits with ZIPA. A TISEZA certificate does not authorise a Zanzibar hotel. A ZIPA licence does not register a Mainland factory. Read the 2025 Act operating guide for the Mainland statute and ZIPA orientation for the islands. Incentives still have to pass the tax law.

People and land follow the premises

A Mainland Class B work permit is not a Zanzibar work authorisation. The live Zanzibar permit guide on this site exists because investors keep making that mistake. Land is the same split: a Mainland derivative right does not title an Unguja plot. Screen land rights before you pay a surveyor on the wrong island.

GN 487A and the islands

The reserved-activity Order discussed on the restricted-list page is reported as a Mainland instrument. Do not assume it reprints in Zanzibar, and do not assume a Zanzibar company opens a reserved Mainland class. Screen the activity where the till actually rings.

Sequence

1. Name the premises: Mainland region or Unguja / Pemba.
2. Name the activity: then screen reserved classes on that side.
3. Pick the registrar: BRELA or BPRA.
4. Open the tax file that matches: TRA and, where relevant, ZRB.
5. Only then talk investment facilitation: TISEZA or ZIPA.
6. Map people and land on the same side of the Union as the premises.

Where this file stalls

• BRELA certificate used as a Zanzibar trading licence
• ZIPA conversation treated as BPRA incorporation
• Mainland work permit for staff living and working in Zanzibar
• One TIN story covering both tax desks without reading Union vs non-Union taxes
• Inventing a filing fee from a blog. Confirm the live registrar; Zatra fees stay on pricing

Currency of this file

Portal names, fee rows and VAT rules move. This page is the split, as at 10 September 2026. Confirm brela.go.tz, bpra.go.tz, tra.go.tz, ZIPA and TISEZA on the day you file.

Worked path: a factory in Pwani vs a hotel in Unguja

A foreign manufacturer wants a plant at Kwala. The premises are Mainland. The company is a BRELA person. Tax is a TRA file. Investment facilitation, if used, is TISEZA. Land is a Mainland derivative-right / general-land story. Work permits are Mainland Labour and Immigration. ZIPA is the wrong building.

A foreign hotelier wants a property near Stone Town. The premises are Zanzibar. The company is a BPRA person. ZIPA may facilitate. Land is a Zanzibar tenure file. Staff need Zanzibar work authorisations. A BRELA certificate in the manager’s drawer does not licence the hotel. TISEZA’s 2025 Act operating guide is useful reading for the Mainland statute. It is not the Unguja licence.

A group that wants both will usually budget two legal persons, two tax calendars, and two permit calendars, or an advocate-designed structure that still files twice where the law requires it. The cheap story is ‘one Tanzania company’. The cheap story is how one side of the Union is always non-compliant.

Banks and the split

A Zanzibar company opening an account in Dar still has to be a Zanzibar person the bank’s KYC can recognise. A Mainland company banking in Zanzibar has the mirror problem. Beneficial-ownership filings follow the registrar you actually used. Do not file BO at BRELA for a BPRA company because the template was handy.

What to put in the board minutes

Write the premises. Write the registrar. Write the tax desks. Write the investment authority if any. If the minutes say ‘Tanzania’ as if it were one counter, the rest of the file will lie in the same way.

Documents that must not be mixed

Keep two folders if you have two persons. Mainland: BRELA extract, TRA TIN, Mainland business licence, TISEZA papers if any, Mainland work permits. Zanzibar: BPRA extract, Zanzibar tax papers, Zanzibar licences, ZIPA papers if any, Zanzibar work authorisations. Sharing a single PDF binder labelled ‘Tanzania setup’ is how a Mainland TIN is offered to a Zanzibar bank and declined.

Beneficial-ownership filings follow the registrar. Annual returns follow the registrar. Struck-off restoration follows the registrar. There is no Union restoration desk that undoes both.

What this page is not

It is not a VAT-rate table. Those rates move and belong on a tax file with a confirm-live stamp. It is not a ZIPA incentive brochure. It is not permission to trade. It is the split. Once the split is chosen, the ordinary setup sequence on that side of the Union applies: identity, tax, licence, bank, people.

Tax calendars that do not copy each other

Mainland VAT, PAYE and corporate income tax are TRA files. Zanzibar non-union taxes are a Zanzibar Revenue Board file. Union taxes still exist, and they are not a licence to ignore the island’s own calendar. A group finance director who diaries only TRA due dates will miss a Zanzibar filing. A hotel accountant who diaries only ZRB will miss a Union obligation. Map both. Confirm the live desks. This page publishes no rate and no due-date, because those rows move in Finance Acts.

Withholding on a cross-border management fee billed to a Zanzibar company is not automatically the Mainland TRA story. Residence of the payer, the place of the service, and which Act applies are an advocate-and-tax file. The Union-versus-non-union orientation exists so this page does not become that treatise. Pick the company first. Then pick the tax desk.

Work permits follow the premises, not the WhatsApp group

A foreign GM sitting in Stone Town on a Mainland work permit is a common stall. Mainland Labour and Immigration instruments do not automatically authorise work in Zanzibar. Zanzibar has its own permit desks. The work-permit keepers on this site already warn about the split. This page is the company-law reason those keepers exist: two legal geographies, two people files.

Directors who never enter Tanzania still exist on the register. They do not replace the permit for the person who will actually manage the plant. Incorporation is not immigration on either side of the Union.