Tax & TRA

Withholding Tax on Dividends Tanzania: 5% and 10% Rates, Treaties, Deadlines and Penalties

Cover: withholding tax on dividends paid by Tanzanian companies under the Income Tax Act Cap. 332 R.E. 2023
Dividend withholding under the Income Tax Act, Cap. 332 R.E. 2023, with the Finance Act 2026 changes. As at 13 October 2026.
Direct answer

What is the withholding tax on dividends in Tanzania? A Tanzanian company withholds 10% of a dividend for resident and non-resident shareholders. The rate is 5% on dividends from a DSE-listed company, and 5% where a resident company holding 25% or more receives the dividend. The tax is final. The company pays it to TRA within seven days after the end of the month of payment.

This guide sets out the rules on withholding tax on dividends Tanzania companies apply: the Income Tax Act sections, the rates by shareholder, treaty claims, branch profits tax, the deemed dividend rule, Zanzibar and a worked example in shillings.

What the law says about withholding tax on dividends

Dividend tax in Tanzania is collected at source. The company that pays the dividend deducts the tax, files a statement and pays it to the Tanzania Revenue Authority (TRA). The shareholder receives the net amount.

The governing law is the Income Tax Act, Cap. 332. TRA publishes the Revised Edition 2023 text, which carries amendments up to Act No. 7 of 2023. The Office of the Chief Parliamentary Draftsman publishes a later R.E. 2023 Annual Supplement 2025, with amendments up to 1 July 2025.

The 2023 revision renumbered the Act. Older notes and TRA letters still cite the 2019 numbers, so check which edition a source uses.

SubjectR.E. 2023 sectionPre-2023 section
Definitions of dividend and distributions.3s.3
Taxation of shareholderss.54s.54
Deemed distribution of retained profits.33A (Finance Act 2025)None
Repatriated income of a domestic permanent establishments.93s.72
Foreign tax reliefs.98s.77
Withholding from investment returnss.105s.82
Statements and payments of tax withhelds.109s.84
Withholding certificatess.110s.85
Final withholding paymentss.111s.86
International agreements (treaties)s.154s.128

The R.E. 2023 numbers above come from the arrangement of sections in the TRA copy. The online text of both R.E. 2023 copies stops before section 54, so the operative wording quoted below comes from the TanzLII consolidation as at 30 November 2019. Rates come from TRA's own tables and the Zatra fee register.

Section 54(1)(a) in that text says a dividend distributed by a resident corporation is taxed in the shareholders' hands "in the form of a final withholding tax". Section 54(1)(b) says a dividend from a non-resident corporation is included in the shareholder's income instead.

Who is affected

Companies registered in Zanzibar are covered too, because income tax is a Union tax. The Zanzibar section below explains what differs.

What counts as a dividend for tax purposes?

Section 3 of the Act defines a "dividend of an entity" as "a distribution by the entity to the extent that it is not a repayment of capital". The definition of "distribution" is wider than a cash dividend declared at a general meeting.

Per the TRA text, a distribution covers payments by an entity to a member beyond what the member paid in, reinvested dividends that increase share value, and capitalisation of profits. It also covers amounts paid on cancellation, redemption or surrender of a membership interest.

Three practical points follow.

Section 57, headed "Income or dividend stripping", sits alongside these rules as an anti-avoidance provision. Interest on shareholder loans follows its own rules; see our guide to thin capitalisation.

What are the withholding tax rates on dividends in Tanzania?

TRA's withholding tax page gives three dividend rows. The Zatra fee register records the same rates with their legal basis.

Paying company and recipientResidentNon-residentRegister ID
Company listed on the DSE, any shareholder5%5%F0205
Resident company to a resident company holding 25% or more5%Not applicableF0206
All other dividends, including resident individuals10%10%F0207
Foreign parent in a treaty countryNot applicableLower treaty rate if it appliesTreaty text

The basis is the First Schedule to the Act, paragraph 4(b), read with section 54(2). TRA's Taxes and Duties at a Glance 2025/26 repeats the DSE and "other corporations" rows at items 2.0(a)(i) and 2.0(b).

The 25% test has two limbs in the 2019 text of section 54(2). The receiving company must hold 25% or more of the shares and control 25% or more of the voting power, directly or indirectly. PwC's withholding summary, last reviewed on 9 September 2026, states both limbs.

Two common misreadings cause most errors:

Investors buying listed shares should read our guide on how to buy shares on the DSE. The listing itself drives the 5% rate.

Is withholding tax on dividends a final tax?

Yes, for dividends paid by a resident company. Section 54(1)(a) taxes them by final withholding, and section 111 deals with final withholding payments. PwC's income determination summary confirms that dividend withholding "is a final tax".

A final tax means the shareholder does not add the dividend to taxable income and cannot claim a credit for the tax withheld. A resident individual with only dividend income has no further income tax to pay on it. A resident company excludes the dividend from its corporate income tax computation.

Dividends a Tanzanian company receives from a foreign subsidiary are different. Section 54(1)(b) includes them in income, and foreign tax relief under section 98 may reduce the Tanzanian tax. Our guide to the corporate income tax return covers how that income is reported.

What changed in the Finance Acts 2025 and 2026?

No Finance Act from 2023 to 2026 changed the three dividend rates. The material change is a new rule that taxes retained profit as if it were paid out.

The Finance Act, 2025 (No. 11 of 2025), in force on 1 July 2025, inserted section 33A, headed "Avoidance of tax liability by non distribution of dividends". Where the Commissioner determines that an entity has not distributed for twelve months after the end of a year of income, he may treat thirty percent of its profit as distributed on that date.

The Finance Act, 2026 (No. 2 of 2026), assented on 30 June 2026 and in force on 1 July 2026, replaced "thirty" with "fifteen" in section 33A(1). It also added exclusions.

PointFinance Act 2025Finance Act 2026
Share of profit deemed distributed30%15% (F0202)
TriggerNo distribution within 12 months after year end, and a Commissioner determinationUnchanged
Tax on the deemed amountDividend withholding, reported at 10%Unchanged
ExclusionsA resident entity covered by section 96(6)Adds DSE-listed companies, financial institutions, insurers and mining companies with a Framework Agreement
Later actual dividendNo withholding on the amount already deemed distributedUnchanged

Independent notes agree on the mechanics. Clyde & Co (3 July 2025) and EY (4 August 2025) describe the 30% rule and 10% withholding. Clyde & Co (3 July 2026) and EY (17 July 2026) report the cut to 15% and the new exclusions.

EY reads the section 96(6) proviso as excluding resident corporations with foreign ownership, which TRA treats under the controlled foreign corporation rules. We did not read section 96(6) this session. A foreign-owned subsidiary should confirm its position before relying on that reading.

How do treaty rates reduce dividend withholding?

A double tax agreement can cap the Tanzanian tax on a dividend paid to a resident of the other country. It cannot raise it. Where the treaty rate is higher than 10%, the domestic rate applies. PwC lists nine treaties in force.

Treaty partnerTreaty dividend rateRate that applies in practice
India5% (company holding at least 25%) or 10%5% or 10%
Zambia0% (domestic rate if exempt in Zambia)0% or 10%
Italy; South Africa10%; 10% or 20%10%
Canada; Denmark; Finland; Norway; Sweden15% to 25%10% domestic rate

The India rate is confirmed by the Government of India table of treaty withholding rates, which gives 5% where the recipient company owns at least 25% of the payer. The others are from PwC. The Habib Advisory Tanzania Tax Guide 2025/2026 lists the same nine countries.

To claim a treaty rate, the withholding agent needs evidence before it pays:

  1. A certificate of residence from the tax authority of the treaty country, covering the year of payment.
  2. Evidence that the shareholder is the beneficial owner of the dividend, not a conduit.
  3. The shareholding on the payment date, from the register of members, where the treaty rate depends on it.
  4. The treaty article and any protocol, read in the current text.

Our guide to Tanzania's double tax treaties covers residence papers and beneficial ownership tests. If the company withholds at 10% and the treaty allows 5%, recovering the excess means a refund claim to TRA. That takes longer than getting the rate right at payment.

How are branch profits taxed instead of dividends?

A branch of a foreign company cannot pay a dividend, because it has no shareholders of its own. The Act taxes the profit a branch sends home instead. Section 93 covers the "repatriated income of domestic permanent establishment".

A domestic permanent establishment pays corporate income tax at 30% on its income (F0196). It then pays 10% on its repatriated income (F0201), under First Schedule paragraph 3(4). TRA's Glance lists the 10% rate at item 1.0(j).

The repatriated amount is computed by a formula in section 93 that looks at movements in the branch's net assets. We could not read that formula in the R.E. 2023 text this session. Have the computation checked before the corporate return is filed. Our comparison of branch, subsidiary or new local company sets out the wider trade-offs.

When can a company lawfully pay a dividend?

Tax is the second question. The first is whether company law allows the payment. Section 183 of the Companies Act, Cap. 212 R.E. 2023, is headed "Dividends", according to the arrangement of sections in the BRELA copy of the Act. It was section 180 in the 2002 numbering.

PwC Tanzania's overview of the Companies Act 2002 summarises section 180(3). A dividend may be paid out of realised profits less realised losses, or realised revenue profits less revenue losses. The directors must also reasonably believe that, after payment, the company can pay its debts as they fall due and its assets exceed its liabilities.

The articles set who declares. Breakthrough Attorneys (16 January 2017) describe the usual pattern. The board recommends a final dividend for approval at the annual general meeting, and may pay interim dividends between meetings.

Paying a foreign shareholder also involves the bank. It will ask for the accounts, resolutions and proof that withholding tax was paid before it remits under Bank of Tanzania rules. Our guide to repatriating profits, dividends and capital lists the bank pack.

How do you file and pay dividend withholding tax?

TRA's page states that "every withholding agent shall pay to the Commissioner within seven days after the end of each calendar month" the tax withheld. The Glance gives the same deadline for the statement of tax withheld. The rule sits in section 109 of the Act.

  1. Deduct at payment. Pay the shareholder the net amount and hold the tax.
  2. File the statement. Lodge the monthly withholding statement on the TRA portal, naming each recipient and amount.
  3. Pay against a control number. Pay the tax by bank or mobile money against the GePG control number the portal issues.
  4. Issue certificates. TRA says withholding certificates are printed from the Taxpayer Portal after payment. Send one to each shareholder.

A dividend paid on 20 October 2026 must be reported and paid by 7 November 2026. Our guide to withholding tax on local payments covers the same monthly cycle for rent, interest and fees.

What happens if dividend withholding is late or missed?

Interest and penalties come from the Tax Administration Act, Cap. 438, not the Income Tax Act. Zatra's separate guide to TRA penalties and interest, published on 13 October 2026, explains each section in detail.

ConsequenceAmountBasisRegister ID
Late filing or payment penalty, each month or partHigher of 2.5% of unpaid tax or 15 currency points (TZS 300,000) for a companyCap. 438 s.89NEW-02-06
Interest on late taxStatutory rate, compounded monthlyCap. 438 s.87NEW-02-08
Statutory rate, 3rd quarter 20268.75%Bank of Tanzania rateNEW-02-09
Currency pointTZS 20,000Cap. 438 s.4NEW-02-05

A company that fails to withhold is still liable for the tax. It pays from its own funds and cannot recover the interest from the shareholder. Directors should treat dividend withholding as trust money, not working capital.

A deliberate failure can also become an offence, and an assessment can be challenged by objection and appeal. Both belong with an advocate. Our TRA audit and dispute service prepares the file for that advocate.

How does this apply in Zanzibar?

Section 2 of the Income Tax Act states: "This Act shall apply to Mainland Tanzania as well as Tanzania Zanzibar." Income tax is a Union tax, administered by TRA on both sides. The Zanzibar Revenue Authority collects Zanzibar's own taxes, such as VAT under Zanzibar law, but not income tax.

PointMainland TanzaniaZanzibar
Dividend withholding lawIncome Tax Act, Cap. 332Same Act (s.2)
Collecting authorityTRATRA
Rates5% or 10%Same
Company law on distributable profitCompanies Act Cap. 212, s.183Zanzibar Companies Act No. 15 of 2013; rule not verified
Company registrarBRELABPRA

The Act also has section 99, headed "Tax credit for business or investment operating in both Mainland Tanzania and Tanzania Zanzibar". Groups with companies on both sides should check it. Our guide to Union and non-Union taxes explains the split.

Worked example: TZS 500 million to a foreign parent and Tanzanian shareholders

The facts. Mwanzo Foods Ltd is a resident, unlisted company on the Mainland. Its approved accounts show distributable profit, and its AGM declares a final dividend of TZS 500,000,000. A foreign parent in a country with no treaty with Tanzania holds 60%. Tanzanian resident individuals hold 40%. The company pays on 20 October 2026.

ShareholderGross dividend (TZS)RateTax withheld (TZS)Net paid (TZS)
Foreign parent, 60%300,000,00010% (F0207)30,000,000270,000,000
Resident individuals, 40%200,000,00010% (F0207)20,000,000180,000,000
Total500,000,00050,000,000450,000,000

The company files the October withholding statement and pays TZS 50,000,000 to TRA by 7 November 2026. The tax is final for every shareholder.

The treaty case. Now assume the 60% parent is resident in India, holds a certificate of residence for 2026 and is the beneficial owner. The India treaty rate for a company holding at least 25% is 5%. Tax on the parent's share falls to TZS 15,000,000, and the parent receives TZS 285,000,000. Total withholding is TZS 35,000,000, a saving of TZS 15,000,000.

The domestic group case. If the 60% holder were a Tanzanian resident company holding the shares and votes, the 5% rate under F0206 would apply. Its tax would also be TZS 15,000,000.

The late case. Return to the first set of facts. The company pays the TZS 50,000,000 on 5 January 2027 instead of 7 November 2026. That is one month and 29 days late, so two months or part.

TRA's system computes the official figures, and the statutory rate for the fourth quarter of 2026 may differ.

The deemed dividend case. Pwani Grain Ltd is wholly owned by Tanzanian individuals. It makes TZS 800,000,000 of profit in the year to 31 December 2025 and pays no dividend by 31 December 2026. If the Commissioner applies section 33A, 15% or TZS 120,000,000 is treated as distributed on that date. Withholding at 10% is TZS 12,000,000 (F0202).

What to do now

  1. Confirm distributable profit. Use approved accounts and record the directors' solvency view before any declaration.
  2. Map each shareholder. List residence, entity type, shareholding and voting power on the payment date from the register of members.
  3. Set the rate per shareholder. Apply 10%, or 5% for a DSE-listed payer or a qualifying resident company, and record the basis.
  4. Collect treaty evidence early. Ask foreign shareholders for a current certificate of residence and beneficial ownership confirmation before the payment date.
  5. Diary the deadline. File the statement and pay within seven days after the end of the month of payment.
  6. Issue certificates. Print withholding certificates from the TRA portal and send them with the remittance advice.
  7. Prepare the bank pack. Give the bank the accounts, resolutions and TRA payment receipt for any foreign remittance.
  8. Review retained profit. Check whether section 33A could deem part of last year's profit distributed, and decide on a dividend policy.

Key dates and deadlines

WhenWhatBasis
Before declarationApproved accounts and board solvency viewCompanies Act Cap. 212 s.183
Payment dateDeduct tax at the applicable rateCap. 332 s.105 and First Schedule
Within 7 days after the end of the payment monthFile the withholding statement and pay TRACap. 332 s.109; TRA withholding page
After paymentIssue withholding certificatesCap. 332 s.110; TRA portal
Each month or part after the deadlinePenalty and interest accrueCap. 438 ss.87 and 89
12 months after the year endSection 33A deemed distribution may applyCap. 332 s.33A; Finance Act 2026
1 July 2026Deemed share cut from 30% to 15%Finance Act 2026 s.22

Checklist for paying a dividend

DocumentWho prepares itWhy it matters
Approved or audited accountsFinance team and auditorShows distributable profit
Board minute and shareholder resolutionCompany secretaryAuthorises the dividend under the articles
Register of members extractCompany secretaryFixes holdings for the rate and the 25% test
Certificate of residenceForeign shareholderSupports any treaty rate
Withholding statement and payment receiptFinance teamProves the tax reached TRA
Withholding certificateTRA portalEvidence for the shareholder and the bank

How Zatra helps

Zatra's tax advisory and planning service reviews a dividend before it is declared. That covers distributable profit, the rate per shareholder, treaty evidence and the section 33A position. Our tax compliance service files the monthly statements and certificates. The Finance & Tax Control package, USD 3,600 to 4,800 a year, includes routine withholding filings. A Senior Advisory Session at USD 49 suits a single dividend question. Prices are on our pricing page.

Tax, penalties and interest are paid to TRA at the official amount against a GePG control number. These government charges are separate from Zatra's professional fee and are never marked up. Our government fees handbook lists the official figures.

TRA decides assessments, refunds and treaty claims. Zatra prepares and coordinates the file; it does not decide or guarantee any authority's outcome. An objection, an appeal to the Tax Revenue Appeals Board, a prosecution or a formal legal opinion on an unlawful dividend goes to an advocate on our team.

Sources and status

Accurate as at 13 October 2026. Rates are from TRA and the Zatra fee register at 26 September 2026; legal text is from the versions listed below.

Figures to confirm before you act

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 resident individual declare dividends in an annual tax return?

Not for dividends from a Tanzanian company that withheld the tax. The withholding is final, so the dividend stays out of the individual's taxable income. Keep the withholding certificate in case TRA or a bank asks for proof.

Is a scrip dividend or bonus issue taxed?

It can be. The Act's definition of distribution includes capitalisation of profits and reinvested dividends that increase share value. Before issuing shares from reserves, confirm with a tax adviser whether withholding applies and at what value.

Can a holding company in Mauritius or the UAE use a treaty rate?

Only if Tanzania has a treaty in force with that country. Neither appears on PwC's list of nine treaties in force, so the 10% domestic rate applies unless TRA's current list says otherwise. Check before relying on a treaty that is signed but not in force.

Who pays the tax if the company forgets to withhold?

The company. A withholding agent that fails to deduct remains liable for the tax, with penalty and interest from the due date. Recovering the shortfall from shareholders afterwards is a private matter, and the interest cannot be passed on.

Does withholding apply to a dividend declared but not yet paid?

Withholding attaches to payment. Where a dividend is credited to a shareholder's loan account instead of paid in cash, TRA may treat the credit as payment. Confirm the treatment before booking a large declared dividend that will sit unpaid.

Is interest on a shareholder loan taxed like a dividend?

No. Interest is a separate payment type with its own withholding row, and thin capitalisation rules can limit the deduction for the company. A payment called interest that is in substance a profit share may be challenged.

How long should a company keep dividend records?

Keep the accounts, resolutions, register extracts, treaty papers, statements, receipts and certificates for at least the period TRA can reopen a year. Banks also ask for the previous dividend file when a new remittance is requested.

Can a Zanzibar company pay its dividend withholding to ZRA?

No. Income tax is a Union tax under the Income Tax Act, which applies in Zanzibar. Dividend withholding goes to TRA, which has offices in Zanzibar. The Zanzibar Revenue Authority collects Zanzibar's own taxes, such as VAT under Zanzibar law.

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.

Brief the desk

This Insights page is orientation. Tax advisory and planning is the commercial desk for the same facts. Zatra’s fee stays on its own line, separate from government, bank and regulator charges. Approvals are not guaranteed.

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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/.

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