Permanent Establishment Tanzania: When a Foreign Company Becomes Taxable Here
When does a foreign company have a permanent establishment in Tanzania? Under section 3 of the Income Tax Act, Cap. 332, a foreign company has a permanent establishment wherever it carries on business in Tanzania. That includes a dependent agent, substantial equipment, and a construction or installation project lasting six months or more. Its Tanzanian profit is then taxed at 30%, plus 10% on profit repatriated abroad.
This guide explains the permanent establishment Tanzania rules for foreign companies that work here without a local subsidiary. It covers the statutory definition, the six-month construction test, dependent agents, how a treaty can change the answer, branch registration at BRELA, the TIN, the 15% withholding on service fees, TRA practice and Zanzibar. A worked example uses dollar and shilling figures.
Who should read this
- Foreign contractors building, installing or commissioning plant, roads, towers or factories in Tanzania.
- Foreign consulting, engineering and IT firms that send staff to Tanzanian clients for months at a time.
- Foreign suppliers that use a local agent to sign contracts, issue invoices or hold stock.
- Foreign companies leasing or operating substantial equipment such as rigs, cranes or drilling plant.
- Tanzanian clients paying these firms, because they carry the withholding obligation and the audit questions.
- Group finance teams choosing between a branch and a subsidiary.
If you are still choosing a vehicle, read our comparison of branch, subsidiary or new local company first. This guide assumes the foreign company itself is doing the work.
What the law says
The rule starts in the Income Tax Act, Cap. 332 R.E. 2023, as published by the Tanzania Revenue Authority (TRA). Section 3 defines a permanent establishment as "a place where a person carries on business". It then lists three cases that are always included:
- Dependent agent. A place where the person carries on business through an agent, other than a general agent of independent status acting in the ordinary course of business.
- Substantial equipment. A place where the person has used or installed, or is using or installing, substantial equipment or substantial machinery.
- Construction projects. A place where the person is engaged in a construction, assembly or installation project for six months or more, including supervisory activities on that project.
A proviso to the agent limb deems a permanent establishment where a dependent agent habitually concludes contracts or issues invoices for the foreign company. The same applies where the agent habitually keeps stock and delivers from it, or habitually secures orders wholly or almost wholly for the company or its group. An agent that only buys goods for the company is excluded.
The R.E. 2023 renumbered the Act. The permanent establishment provisions are now section 91 (principles of taxation), section 92 (calculating income of a permanent establishment) and section 93 (repatriated income of a domestic permanent establishment). Older guides cite them as sections 70 to 72, the numbers in the R.E. 2019 text on the Ministry of Finance site. Section 4(1)(b) charges tax on a person with a domestic permanent establishment that has repatriated income for the year.
Is there a 183-day or service permanent establishment rule in Tanzanian law?
No. The domestic definition has no day count for services. The only time test in section 3 is the six-month rule for construction, assembly and installation projects. PwC Worldwide Tax Summaries, last reviewed on 9 September 2026, describes the same three limbs and no services limb.
That does not make short visits safe. The opening words, "a place where a person carries on business", have no minimum period. A foreign firm with a fixed site office, a desk at a client, or staff who run its business from a Tanzanian address can meet that test well before six months.
The 183-day figure comes from tax treaties. Many treaties add a "service permanent establishment" where staff furnish services in the other country for more than 183 days in a twelve-month period. That threshold protects a treaty resident; it does not appear in Tanzanian domestic law.
How is the six-month construction test applied?
The test asks whether the foreign company "is engaged" in a construction, assembly or installation project for six months or more. Supervisory work on the project counts. A foreign company that only supervises a local subcontractor can still meet the test.
Four practical points follow from the wording:
- The clock runs on the project, not on any one employee's days in Tanzania.
- Commissioning, testing and defects work at the site can extend the project.
- Splitting one project into several contracts to stay under six months invites a TRA challenge.
- The substantial equipment limb has no time limit, so a rig or crane on site may create a permanent establishment on day one.
The Act does not set out how breaks in work or connected contracts are counted. Treat those points as open and document the project timeline from the start.
How is a permanent establishment taxed?
Two charges apply to a foreign company with a domestic permanent establishment on the Mainland and in Zanzibar, because income tax is a Union tax administered by TRA.
| Charge | Rate | Basis | Register ID |
|---|---|---|---|
| Income tax on the permanent establishment's taxable income | 30% | Cap. 332 First Schedule para 3(1) | F0196 |
| Tax on repatriated income of a domestic permanent establishment | 10% | Cap. 332 s.4(1)(b), s.93, First Schedule para 3(4) | F0201 |
| Withholding on dividends paid by a Tanzanian subsidiary, for comparison | 10% | Cap. 332 First Schedule para 4(b)(i)(bb) | F0207 |
The 30% rate is the same as for a resident company. PwC's corporate income page states that it applies to "a PE of a non-resident corporation". The 10% branch charge mirrors the dividend withholding a subsidiary would suffer. The Habib Advisory Tax Guide 2025/2026 describes it as an additional tax on repatriated income under section 93, formerly section 72.
Section 92 computes the income as if the permanent establishment and its head office were independent, with the permanent establishment treated as resident. PwC notes that arrangements between a permanent establishment and its head office are generally not recognised, apart from transfers of assets or liabilities. In practice, management fees, royalties and interest charged by head office need careful support. Our guide to transfer pricing and related-party compliance covers the documentation.
In broad terms, repatriated income is the after-tax profit that leaves the Tanzanian business rather than staying invested in its net assets. The section 93 formula works from changes in the permanent establishment's net assets over the year. Model it on your own balance sheet before you send cash home.
What happens if a foreign company has no permanent establishment?
A foreign company without a permanent establishment is normally taxed at source, through withholding by the Tanzanian payer, rather than through its own return. The TRA withholding tax page lists 15% on service fees paid to non-residents and 5% for residents. The payer remits the tax within seven days after the end of the calendar month.
| Payment to a non-resident | Rate | Register ID |
|---|---|---|
| Service fees, professional and other | 15% | F0212 |
| Technical or management services to mining, oil and gas | 15% | F0213 |
| Royalty | 15% | F0210 |
| Interest | 10% | F0208 |
| Rent of construction equipment and machinery | 10% | F0216 |
The Finance Act 2016 widened the source rule for services. Auditax International (3 February 2022) records that "service rendered" now covers services delivered in Tanzania "irrespective of the place of performance". A foreign firm that never sets foot in Tanzania can still suffer 15% on its fee. Our page on withholding tax on cross-border payments explains the payer's file.
The trade-off is plain. Without a permanent establishment, tax is 15% of the gross fee. With one, it is 30% of net profit plus 10% on what is repatriated. On a low-margin contract, a permanent establishment can cost less than gross withholding, but it brings registration, accounts and returns.
How does a double tax treaty change the permanent establishment test?
Section 154 of the Act gives effect to international agreements. Where a treaty applies, its permanent establishment article decides whether Tanzania may tax the business profits of a resident of the other state. The domestic definition still applies to companies from non-treaty countries.
The South Africa treaty shows how far the two tests can differ. The text published by the South African Revenue Service was signed on 22 September 2005 and entered into force on 15 June 2007. Article 5(3) adds two rules:
- a building site or construction, assembly or installation project is a permanent establishment only if it lasts "more than six months";
- furnishing services, including consultancy, through employees or other personnel creates one where the activities continue "for a period or periods exceeding in the aggregate 183 days in any twelve-month period".
| Point | Tanzanian domestic law (s.3) | Typical treaty (South Africa, Art. 5) |
|---|---|---|
| General test | A place where a person carries on business | A fixed place of business through which business is carried on |
| Construction and installation | Six months or more, supervision included | More than six months |
| Services by staff | No separate rule; general test applies | More than 183 days in any twelve-month period |
| Substantial equipment | Permanent establishment, no time limit | Depends on the treaty wording |
| Dependent agent | Concludes contracts, issues invoices, keeps stock or secures orders | Usually narrower, often limited to concluding contracts |
| Who can rely on it | Applies to everyone | Only a resident of the treaty partner with proof of residence |
Every treaty is different. Some have no services limb at all, and some set longer construction periods. Read the treaty you rely on, and confirm it is in force on TRA's current list. Our guide to Tanzania double tax treaties sets out the residence certificate and beneficial ownership file TRA expects.
A treaty that removes the permanent establishment does not automatically remove the 15% withholding on service fees. That depends on whether the treaty has a separate article on technical or management fees. Check both articles before you price the contract.
Do you have to register a branch at BRELA?
Tax status and company law status are separate questions. A permanent establishment is a tax concept. Registration is a Companies Act duty that arises when a foreign company establishes a place of business in Mainland Tanzania.
Part XII of the Companies Act, Cap. 212 R.E. 2023 governs "companies incorporated outside Tanzania". Sections 437 to 447 cover establishment of a place of business. Section 438 lists the documents to deliver to the Registrar, section 439 provides for the certificate of registration, and section 442 requires the foreign company to file accounts. Section 444 deals with service on the company, and section 445 with cessation of business.
The Registrar of Companies at the Business Registrations and Licensing Agency (BRELA) charges these filing fees, paid on a GePG control number:
| BRELA filing (Part XII foreign company) | Fee | Register ID |
|---|---|---|
| Certified copy of the constitution (charter, memorandum and articles) | TZS 2,000,000 | F0015 |
| Any other required document, except the balance sheet | TZS 600,000 per document | F0016 |
| Balance sheet (accounts) | TZS 600,000 | F0017 |
| Late or non-delivery of a required document | TZS 70,000 per month or part month | F0018 |
| TIN registration at TRA | No fee prescribed | NEW-02-17 |
A registered branch also needs a business licence. A company incorporated abroad pays the foreign-owned (USD) rows of the licence schedule (NEW-08-13). Our step-by-step guide to opening a branch office in Tanzania covers the BRELA file, and our foreign company registration team handles it end to end.
Registration and permanent establishment usually go together, but not always. A foreign firm can have a permanent establishment through a dependent agent without ever opening an office. A registered branch that does no business may have no taxable income. Assess each question on the facts.
What TRA registrations and filings follow?
Under section 22(1) of the Tax Administration Act, Cap. 438, a person must apply for a Taxpayer Identification Number within 15 days of starting business (NEW-02-17). TRA lists the steps on its starting business page. Our TIN registration guide sets out the documents.
Once registered, a permanent establishment runs the same income tax cycle as a resident company. PwC's tax administration summary, last reviewed on 9 September 2026, gives the timetable:
- a statement of estimated tax within three months from the start of the accounting period;
- provisional tax in four equal instalments, at three, six, nine and twelve months;
- a final return within six months after the end of the accounting period, with audited accounts.
The branch also operates PAYE for its staff, withholds on its own payments, and keeps records in Tanzania. Our guides to provisional tax and the corporate income tax return cover each step.
VAT is a separate test. A branch whose taxable turnover reaches TZS 200 million in 12 months, or TZS 100 million in 6 months, must apply within 30 days (F0242). Section 68 of the VAT Act, Cap. 148 R.E. 2023, deals with VAT representatives of non-residents, and section 69 with services from a foreign branch.
How does TRA find and challenge a permanent establishment?
TRA does not wait for a foreign company to self-declare. The usual triggers come from Tanzanian paperwork:
- the client's withholding returns, which name the foreign payee and the contract value;
- work and residence permit files for foreign staff on a project;
- import and customs entries for equipment brought in under the foreign company's name;
- a local agent's invoices, contracts or stock records;
- a tax audit of the Tanzanian client or a group company.
Once TRA concludes that a permanent establishment existed, it can assess income tax from the start of the activity. Late filing carries the higher of 2.5% of the unpaid tax or TZS 300,000 per month for a body corporate (NEW-02-06, NEW-02-05). A false or misleading return attracts 50% of the shortfall, or 75% where knowing or reckless (NEW-02-11). Transfer pricing adjustments to head office charges carry their own penalty (NEW-02-12).
A taxpayer may object within 30 days and must pay the admission deposit (NEW-02-19). Our TRA audit and dispute team prepares the file. Representation before the Tax Revenue Appeals Board, and any legal opinion on permanent establishment status, go to an advocate.
What is the position in Zanzibar?
Income tax is a Union matter, so the Income Tax Act and its permanent establishment rules apply in Zanzibar as on the Mainland, and TRA administers them. The Zanzibar Revenue Authority (ZRA) describes itself as responsible for "all domestic non-union taxes in Zanzibar", such as VAT, hotel levy and stamp duty. Income tax is not on its list.
Company registration is different. A foreign company with a place of business in Zanzibar deals with the Business and Property Registration Agency (BPRA) under the Zanzibar Companies Act, No. 15 of 2013. A BRELA branch registration does not cover Zanzibar. EY (18 January 2023) reports that a 2022 Zanzibar amendment again lets Mainland companies register a branch there instead of a subsidiary.
| Point | Mainland Tanzania | Zanzibar |
|---|---|---|
| Permanent establishment definition | Income Tax Act Cap. 332 s.3 | Same Act (Union tax) |
| Income tax administrator | TRA | TRA |
| Branch registration | BRELA, Companies Act Cap. 212 Part XII | BPRA, Companies Act No. 15 of 2013 |
| VAT | TRA, 18%, threshold TZS 200 million (F0242) | ZRA, 15% standard, threshold TZS 100 million (F0246) |
| Other domestic taxes | TRA and councils | ZRA and Zanzibar councils |
Our guides to registering in Zanzibar at BPRA and Union and non-Union taxes explain the split.
Worked example: an installation contract, with and without a permanent establishment
A foreign engineering company signs a USD 1,200,000 contract to install processing equipment at a factory in Mwanza. We use an illustrative rate of TZS 2,500 to USD 1; use the Bank of Tanzania rate on the day in a real file. The contract is worth TZS 3,000,000,000, and the company expects a 20% net margin.
Scenario A: eight months on site. The project runs for more than six months, so it is a permanent establishment under section 3. It would also be one under a treaty with a "more than six months" rule. The company registers a branch, obtains a TIN and files returns.
| Line | Computation | TZS | USD |
|---|---|---|---|
| Contract value | USD 1,200,000 x 2,500 | 3,000,000,000 | 1,200,000 |
| Net taxable profit | 20% of contract value | 600,000,000 | 240,000 |
| Income tax at 30% (F0196) | 600,000,000 x 30% | 180,000,000 | 72,000 |
| Profit after tax, all sent to head office | 600,000,000 minus 180,000,000 | 420,000,000 | 168,000 |
| Tax on repatriated income at 10% (F0201) | 420,000,000 x 10% | 42,000,000 | 16,800 |
| Total Tanzanian income tax | 180,000,000 + 42,000,000 | 222,000,000 | 88,800 |
The effective rate is 37% of profit, or 7.4% of the contract value. The repatriation line assumes the whole after-tax profit leaves Tanzania in the year; the section 93 formula may give a different figure.
Scenario B: no permanent establishment. Suppose instead the company is a South African resident, the site work lasts five months, no substantial equipment stays behind, and staff spend 150 days in Tanzania. Under the treaty there is no permanent establishment. The Mwanza client still withholds 15% of each payment as a service fee to a non-resident (F0212): 3,000,000,000 x 15% = TZS 450,000,000, or USD 180,000.
That is 75% of the expected profit. On a 20% margin, the permanent establishment route costs about half as much tax, even after the branch charge. The comparison flips on high-margin advisory work, where 15% of gross may be less than 37% of profit.
The cash-flow trap. In Scenario A, a client that keeps withholding 15% on payments to the branch would hold back TZS 450,000,000. That is TZS 228,000,000 more than the branch's total tax. The branch then depends on credit for the tax withheld and on a refund. TRA aims to decide refunds within 90 days of a correct application and pay within 14 days of the decision (NEW-02-23). Agree the withholding position with the client and TRA before the first invoice.
The late-discovery cost. Now suppose the company in Scenario A never registers, and TRA assesses the year three months after the return was due. The late penalty is the higher of 2.5% of TZS 180,000,000, which is TZS 4,500,000, or TZS 300,000, for each month (NEW-02-06). Three months cost TZS 13,500,000 before interest. At the BRELA end, each document delivered eight months late adds TZS 560,000 at TZS 70,000 a month (F0018).
What to do now
- Map the activity. List every Tanzanian contract, site, agent and piece of equipment, with start and expected end dates.
- Test the domestic definition. Check the general test, the agent proviso, the equipment limb and the six-month construction rule under section 3.
- Read the treaty. Confirm the treaty is in force, read its permanent establishment and fee articles, and obtain a residence certificate.
- Model both routes. Compare 15% withholding on gross fees with 30% on profit plus 10% on repatriated income, using your real margin.
- Register if the answer is yes. File the Part XII documents at BRELA, or at BPRA for Zanzibar, then apply for a TIN within 15 days of starting business.
- Agree withholding with the client. Settle in writing how payments to the branch will be treated, so cash is not trapped.
- Price head office charges. Document any management, royalty or interest charges to the branch under transfer pricing rules.
- Diarise the calendar. Set the estimate, the four instalments, the final return and the monthly withholding dates.
Key dates
| When | What | Source |
|---|---|---|
| Within 15 days of starting business | Apply for a TIN | TAA s.22(1); NEW-02-17 |
| Six months into a construction or installation project | Domestic permanent establishment threshold | Cap. 332 s.3 |
| More than 183 days in any twelve months | Service permanent establishment, where the treaty has one | Treaty Art. 5 |
| Within 7 days after each month end | Payer remits tax withheld on service fees | TRA withholding page |
| Three months from the start of the accounting period | Statement of estimated tax | PwC tax administration |
| Months 3, 6, 9 and 12 of the accounting period | Provisional tax instalments | PwC tax administration |
| Six months after the end of the accounting period | Final return of income | PwC tax administration |
| Within 30 days of crossing the VAT threshold | Apply for VAT registration | F0242 |
| Within 30 days of an assessment | Objection, with the admission deposit | TAA s.62; NEW-02-19 |
How Zatra helps
Zatra reviews a foreign company's Tanzanian activity against section 3 and the relevant treaty, and writes up the position for the board and the auditors. We model the withholding and branch routes on your real numbers. Where registration is needed, we prepare the BRELA or BPRA file, the TIN application and the first-year tax calendar.
Our tax advisory and planning desk leads the analysis. Our TIN and VAT registration team handles TRA, and our TRA audit and dispute team handles assessments and objections. For profits leaving Tanzania, see our guide to repatriating profits, dividends and capital.
Costs come in two separate buckets. Government charges, such as the BRELA filing fees above, are paid at the official rate on a GePG control number. Zatra's professional fee is quoted on its own line and never mixed with government charges. Zatra prepares and files, but does not decide or guarantee any authority's outcome. Formal legal opinions, prosecutions, seizures and disputes before the Board or the courts go to an advocate.
Sources and status
Accurate as at 19 October 2026.
- Income Tax Act, Cap. 332 R.E. 2023: TRA copy, 2025 print; s.3, s.4 and the arrangement of ss.91 to 93, 106 and 154 read. Accessed 19 Oct 2026.
- TRA withholding tax page: TRA, 2026. Accessed 19 Oct 2026.
- Companies Act, Cap. 212 R.E. 2023: BRELA copy, 2023; Part XII. Accessed 19 Oct 2026.
- South Africa and Tanzania tax treaty: SARS, signed 22 Sep 2005, in force 15 Jun 2007. Accessed 19 Oct 2026.
- PwC Worldwide Tax Summaries, Tanzania: PwC, last reviewed 9 Sep 2026. Accessed 19 Oct 2026.
- Habib Advisory Tax Guide 2025/2026: Habib Advisory, 2025. Accessed 19 Oct 2026.
- Zatra fee register lines F0015, F0016, F0017, F0018, F0196, F0201, F0207, F0208, F0210, F0212, F0213, F0216, F0242, F0246, NEW-02-05, NEW-02-06, NEW-02-11, NEW-02-12, NEW-02-17, NEW-02-19, NEW-02-23, NEW-08-13, F0182: fees at 26 Sep 2026. Accessed 19 Oct 2026.
Figures to confirm before you act
- Repatriated income formula: the section 93 computation was not read in full this session; model it on your balance sheet with an adviser
- Withholding on payments to a registered branch: whether TRA expects 15% or 5%, and whether it is credited against the branch's tax
- Finality of the 15% withholding: whether it is final for a non-resident with no permanent establishment, under s.111
- Counting the six months: how TRA treats breaks in work and connected contracts
- Treaty status: whether a given treaty is in force and has a services or technical fees article
- BRELA deadline: the period within which s.438 documents must be delivered after a place of business is established
- Zanzibar branch filing: the current BPRA checklist and fees for a foreign company
- Exchange rate: the example uses TZS 2,500 to USD 1 for illustration only
This article is general information based on official sources available at the date of publication. It is not legal, tax or financial advice. Laws and notices change. Verify with the issuing authority or consult Zatra before acting.
Frequently asked questions
Does a single business trip to Tanzania create a permanent establishment?
Usually not on its own. A short visit to meet a client or negotiate a contract rarely amounts to carrying on business through a place in Tanzania. The risk rises when the visitor signs contracts, issues invoices, works from a fixed desk, or the visits add up across a project.
Can a home-based employee in Dar es Salaam create a permanent establishment for a foreign employer?
It can. If the employee habitually concludes contracts or secures orders for the employer, the agent proviso may apply. A home office used regularly for the employer's business can also be a place of business. Review the role description and the authority the employee holds.
Is a liaison or representative office a permanent establishment?
Tanzanian domestic law has no general exemption for preparatory or auxiliary activities. Many treaties do, for places used only for storage, display, purchasing or collecting information. A liaison office that negotiates sales or supports delivery is likely to be treated as carrying on business.
Does a subsidiary create a permanent establishment for its foreign parent?
Not by being a subsidiary. A Tanzanian company is a separate resident taxpayer. The parent can still have a permanent establishment if the subsidiary acts as its dependent agent, for example by signing contracts in the parent's name, or if parent staff run a site directly.
Can a branch carry tax losses forward?
A permanent establishment computes its income as if it were a separate resident person, so the ordinary loss rules apply to its own Tanzanian business. Head office losses abroad cannot be set against Tanzanian profit. Check the current loss limitation rules before you rely on a carry-forward.
Does closing the branch end the permanent establishment tax file?
Not immediately. The branch should file final returns, settle withholding and PAYE, obtain tax clearance and deliver its cessation notice to BRELA under section 445. Assets sent abroad on closure may count in the repatriated income computation, so plan the timing.
Do foreign staff on a permanent establishment project pay Tanzanian tax?
Usually yes. Employment income for work done in Tanzania has a Tanzanian source, and a branch must run PAYE for its staff. Non-resident employees are taxed at 15% as a final withholding (F0182). Each person also needs the right work and residence permits.
Can Zatra give a formal opinion that no permanent establishment exists?
Zatra prepares the technical analysis, models the tax and assembles the evidence. A formal legal opinion that a bank, auditor or TRA will rely on is issued through an advocate. TRA decides the tax position, and an appeal goes to the Tax Revenue Appeals Board.
Sources & regulators
Verify before filing: Rates, forms and thresholds move by Finance Act, Government Notice and portal revision. Confirm the live schedule on the mandate-holder portal before you budget or submit. Law-firm alerts and Big Four notes are discovery only.
- The Income Tax Act, Cap. 332 R.E. 2023: Tanzania Revenue Authority, Revised Edition 2023, 2025 print; s.3 definition of permanent establishment, s.4(1)(b) and arrangement of ss.91 to 93, 106 and 154 read 19 Oct 2026; primary source. Accessed 2026-10-19.
- The Income Tax Act, Cap. 332 R.E. 2019: Ministry of Finance, Revised Edition 2019; former numbering ss.70 to 72; primary source. Accessed 2026-10-19.
- TRA: Withholding tax: Tanzania Revenue Authority, live page 2026, read 19 Oct 2026; 15% non-resident service fees, remittance within 7 days after month end; primary source. Accessed 2026-10-19.
- TRA: Starting business: Tanzania Revenue Authority, live page 2026, read 19 Oct 2026; TIN registration; primary source. Accessed 2026-10-19.
- The Companies Act, Cap. 212 R.E. 2023: BRELA, Revised Edition 2023; Part XII ss.437 to 447 (foreign companies); primary source. Accessed 2026-10-19.
- Agreement between South Africa and Tanzania for the avoidance of double taxation: South African Revenue Service, Government Gazette 30039 of 4 Jul 2007; signed 22 Sep 2005, in force 15 Jun 2007; Art. 5(3) read; primary source. Accessed 2026-10-19.
- ZRA: Zanzibar Revenue Authority: Zanzibar Revenue Authority, live site 2026, read 19 Oct 2026; administers domestic non-union taxes; primary source. Accessed 2026-10-19.
- Zanzibar Companies Act, No. 15 of 2013: Business and Property Registration Agency, Zanzibar, Act of 2013, copy posted Feb 2025; primary source. Accessed 2026-10-19.
- PwC Worldwide Tax Summaries: Tanzania, Corporate residence: PwC, last reviewed 9 Sep 2026; independent source on the PE definition and agent proviso. Accessed 2026-10-19.
- PwC Worldwide Tax Summaries: Tanzania, Taxes on corporate income: PwC, last reviewed 9 Sep 2026; independent source on the 30% rate for a PE. Accessed 2026-10-19.
- PwC Worldwide Tax Summaries: Tanzania, Tax administration: PwC, last reviewed 9 Sep 2026; independent source on return and instalment dates. Accessed 2026-10-19.
- Habib Advisory: Tanzania Tax Guide 2025/2026: Habib Advisory, 2025 (2025/26 edition); independent source on the 10% tax on repatriated income under s.93, formerly s.72. Accessed 2026-10-19.
- Auditax International: Withholding Tax System in Tanzania: Auditax International, 3 Feb 2022, updated 19 Feb 2025; independent source on the Finance Act 2016 services source rule. Accessed 2026-10-19.
- EY: Companies incorporated in Tanzania Mainland no longer required to register a subsidiary in Zanzibar: EY Tax News Update, 18 Jan 2023; independent source on the Zanzibar 2022 amendment. Accessed 2026-10-19.
Disclaimer
This article is informational orientation. It is not legal, tax or investment advice and not a government decision. Tanzanian instruments move by Act, Government Notice, Finance Act and portal revision. If a sentence here disagrees with the live mandate-holder, the mandate-holder wins. Zatra Consultants Limited does not issue licences, permits, tax clearances or approvals, and gives no assurance of any regulatory or banking outcome. Professional fees are published only on /pricing/.