Opening a Seychelles holding company bank account: structure and transparency

Why a holding is based in the Seychelles

A Seychelles holding company bank account is usually held by an IBC that owns shares in foreign companies. It receives dividends and sale proceeds, and the bank requires a full group chart, the origin of the capital and evidence of suitable substance. Family groups from the Indian Ocean, East Africa or the Gulf use this structure for regional subsidiaries, but must explain the choice economically.

Family groups from the Indian Ocean, East Africa or the Gulf use a Seychelles IBC to hold regional subsidiaries, notably in tourism or trading. The bank expects an economic explanation for choosing the islands, beyond tax.

Foreign dividends and territorial taxation

Since a territorial system was adopted in 2019, foreign-source income of a Seychelles company is in principle exempt. For large entities, however, this exemption of passive income is kept only if they meet the substance requirements.

The substance test for a pure holding

For a company that only holds shares, the most common case of a Seychelles holding company bank account, the substance required is lighter: complying with corporate obligations and having adequate staff and premises for that activity, possibly provided by a licensed service provider. Banks ask how this is organised.

A fully documented ownership chain

To open a holding bank account, the bank asks for registers of each subsidiary, certificates of incorporation and the chart up to the individuals. A Seychelles holding owning a Mauritian or Emirati company must be able to show recent, certified documents at every level.

Withholding tax in the subsidiaries' countries

Dividends paid by a foreign subsidiary to a Seychelles holding bear the withholding tax of the subsidiary's country, reduced only where a tax treaty with the Seychelles provides for it, a smaller network than major centres have. The bank takes this into account.

Directors and decision-making

Directors supplied by a local provider are not enough if all decisions are taken elsewhere. Minutes, signatures and the place of meetings show where the holding is actually managed, which may determine its tax residence.

French rules on controlled foreign companies

A French-resident shareholder who controls a Seychelles holding may be taxed in France on its profits under article 209 B or 123 bis of the French tax code. The bank does not rule on this, but the shareholder must assess it.

A dollar account to receive regional dividends

Most Seychelles holdings operate in US dollars, the currency of regional flows. Transfers go through correspondent banks in New York or Europe, which may ask for distribution minutes and the paying subsidiary's accounts.

Domestic bank and international holdings

Seychelles Commercial Bank focuses mainly on Seychellois customers; a foreign-owned holding with no local activity will need a particularly strong file and may be directed towards other banks in the islands that are more used to international structures.

Transparency: CRS, central register and good practice

For a passive holding, beneficial owners are reported under CRS to their country of residence, and their names sit in the central database available to the authorities. A legitimate Seychelles structure relies on that transparency, not on discretion.

Steps to open a Seychelles holding company bank account

Opening generally follows five stages: incorporating the IBC through a registered agent, gathering the documents of the company and its shareholders, choosing the bank, submitting the file with the group chart, and then compliance review. Each stage takes time, especially when subsidiaries are located in several countries and documents must be legalised.

Prepare the certificate of incorporation, the articles, the holding's registers, certified identity documents of the beneficial owners, recent proof of address and a description of the expected activity. Add the documents for each subsidiary held and, if possible, a statement of shareholdings with percentages. An orderly, consistent and dated file spares the bank from making repeated requests for further documents.

Refusals most often stem from an incomplete group chart, a weak economic explanation for choosing the islands, directors whose real role is unclear or a poorly documented source of capital. For a Seychelles holding company bank account, the bank wants to understand why the structure exists, what it holds and who really benefits. A precise answer is worth more than a long speech.

Seychelles holding company: documents and questions to anticipate

Before submitting the file, list the likely questions: what is the nature of the subsidiaries, what share of capital is held, where did the contributed funds come from, which dividends are expected and when. Prepare written answers, with contracts, subsidiaries' annual accounts or shareholder agreements. This anticipation shortens exchanges and shows that the directors control the structure. These details help the bank assess the structure quickly.

Banks also look at governance: who signs, who decides, where the directors meet and how decisions are recorded. Regular signed minutes, clearly defined mandates and up-to-date accounts strengthen the holding's credibility. Conversely, backdated documents or papers drafted after the event create distrust and can lead to the closure of an account. Written answers also help your advisers. Prepare them calmly and keep copies.

Ask the bank which fees apply to maintaining the account, to international payments and to the annual review of the file, and whether a minimum deposit is required. Find out whether online banking is available and what transfer limits apply. These conditions vary from one institution to another and weigh on the real cost of a holding company account in the Seychelles over several years.

Holding bank account: flows, currencies and correspondents

A holding account mainly receives dividends, loan repayments and sale proceeds, and is used to pay distributions or to fund subsidiaries. These flows must match the scheme presented at opening. A movement unrelated to holding shares, such as receipts from customers, attracts the bank's attention and may trigger a request for justification. The earlier you gather these papers, the smoother the review.

Most holdings operate in US dollars or euros, with payments routed through correspondent banks abroad. These correspondents also screen transfers and may ask for the distribution minutes, the loan agreement or the paying subsidiary's accounts. Prepare these documents in advance, because an unjustified transfer can stay blocked for several days. Compare at least two banks on these terms. This also helps your auditors.

Keep amounts received, dividends declared and accounting entries consistent. Retain intragroup loan agreements, treasury arrangements and supporting documents for every transfer. This traceability makes the periodic review of a Seychelles holding company bank account easier and protects the structure against suspicion of transactions unrelated to its stated purpose. Document every transfer with a clear reference. It saves time at every review.

Shareholders' reporting and checks before opening a holding account

The bank identifies the holding and the people who control it, then sends the relevant information under CRS to each person's country of residence. Shareholders must therefore declare their holdings and income under their own country's rules. A Seychelles holding company does not exempt them from that duty, and a tax adviser can clarify the consequences of their personal situation.

Check that the registered agent is genuinely authorised by the FSA, that the bank is a supervised institution and that every document carries the exact name of the company. Do not accept an intermediary who guarantees that the account will be opened or who asks for large advance payments: no bank can guarantee its decision before reviewing the full file.

Finally, keep a permanent file containing the articles, registers, minutes, intragroup contracts, subsidiaries' accounts and bank statements. It will be requested during periodic reviews and possibly by the authorities. A holding company account in the Seychelles used in line with the purpose declared at opening limits questions, blocked transactions and the risk of closure. Ask the bank how often it reviews files.