Tax Residency & Worldwide Taxation

Under Sierra Leone's Income Tax framework:

Tax residency is determined by statutory residence tests (including physical presence thresholds and other criteria).

A TRC holder who has no physical presence in Sierra Leone during the tax year and does not meet other residence criteria would generally not be considered tax resident under the standard statutory tests, and therefore would typically only be taxable on Sierra Leone-source income (if any).

Our reference to a "territorial effect" reflects the practical outcome for non-resident TRC holders who do not trigger statutory residence tests. It is not a blanket statutory exemption from worldwide taxation, and we do not represent it as such.