Zanzibar Residency: What the 2023 Act Says

Does buying a home in Zanzibar give a residence permit?#

A buyer of property worth at least USD 100,000 in a real estate project in Zanzibar approved by the Zanzibar Investment Promotion Authority (ZIPA) may be granted resident permits under the Zanzibar Investment Act, 2023, and the operative word is “may”. The Act is Act No. 10 of 2023. The House of Representatives passed it on 4 December 2023, the President assented on 1 February 2024, and under section 1 it came into operation on assent. The permit sits in the Fifth Schedule, Part Four, paragraph 6. Victaura Research read the text in the scanned copy of the assented Act held by FAOLEX, the legal database of the Food and Agriculture Organization. Grade, measured, with the caveat that a scan is not the Gazette.

The permit is one of four incentives in a permissive list. Paragraph 6 says such a buyer “may be granted” resident permits for the buyer, spouse and four children under twenty, a fifty percent exemption on stamp duty, one hundred percent foreign ownership and one hundred percent repatriation of sales proceeds after tax. Section 51 reads more firmly. A buyer who qualifies under criteria prescribed in the regulations “shall be entitled” to the Part Four incentives. The Act does not reconcile the two verbs.

In this article, the buyer permit means the incentive in paragraph 6(a) of Part Four of the Fifth Schedule. It is a resident permit for the buyer, the spouse and up to four children under twenty, available to the buyer of property of a value of not less than USD 100,000 in a real estate project. It is not a visa, a work authorisation or a route to citizenship, and paragraph 6 does not use the label “golden visa”.

The method is narrow. Statute text is graded measured, third-party analysis industry estimate, press reports directional and seller sites broker-reported. Where the Act is silent, this article says so and does not guess.

What does Part Four of the Fifth Schedule say, word for word?#

Part Four is headed “Developer and buyer in real estate projects” and has two operative paragraphs. Paragraph 5 lists what a developer in real estate projects may be granted, a one hundred percent exemption on withholding tax on interest, a one hundred percent exemption on stamp duty per purchase contract, and land and marina lease agreements of thirty-three years each. Paragraph 6 lists the buyer’s four incentives. The buyer paragraph has no definitions, no conditions, no duration and no procedure. Section 51 sends the criteria to regulations.

The Fifth Schedule carries a heading that complicates the reading. It is titled “Incentives for investors in special economic zones”, with a cross reference to section 26. Part Four does not mention zones. Section 51 grants the Part Four incentives to a qualifying buyer without requiring that the project lie in a zone, and the buyer is defined by an approved real estate investment. The plain reading is that the buyer incentives are not confined to zones. That is a reading, without the force of a holding, and no published ZIPA guidance read for this piece settles it. Grade, directional.

Section 26 gives incentives to the Investor, and the Act defines the buyer separately. An Investor is a person granted a Certificate of Investment. Section 51 therefore carries Part Four to the buyer by its own door. The protective machinery written for the certificate holder includes suspension and cancellation in sections 22 and 23, the abandonment rule in section 30 and the transfer approval in section 55. Whether any of it reaches a buyer is not stated.

The Second Schedule sets different numbers, and the two should not be confused. Part One sets the capital threshold for a Certificate of Investment. For a foreign investor, or one jointly owned with a Tanzanian, in hotels and real estate projects it is not less than USD 2.5 million. For a Tanzanian-owned company it is USD 100,000, and for a diaspora-owned one USD 200,000. Those are company-side thresholds. The USD 100,000 in paragraph 6 is a separate test on the value of the property bought. Grade, measured.

Who counts as a buyer under the Zanzibar Investment Act?#

Section 3 defines a buyer, and the definition has five working parts. A buyer is a person who has purchased and has full ownership of real estate property for residential purpose within a real estate investment approved by the Authority. The parts are a purchase, full ownership, residential purpose, a real estate investment and approval by the Zanzibar Investment Promotion Authority (ZIPA). A person who misses one part falls outside the definition. Grade, measured.

Approval belongs to ZIPA and attaches to the project. Section 52 says the Authority shall promote and approve real estate projects in accordance with procedures prescribed in the regulations. A buyer cannot approve a project and cannot cure a missing approval. The first diligence item is therefore a document, ZIPA’s approval of the project, and a brochure line on permits is no substitute for it. The guide on what a buyer can verify in Zanzibar sets out the wider list of checks.

The value test applies to the property, and the Act does not say how value is measured. Paragraph 6 speaks of property “of the value not less than” USD 100,000. It does not say whether value means contract price, appraisal or amount paid, whether smaller purchases can be added together, or at what date value is tested. A developer website reports that one property must reach the threshold (broker-reported, 2024). The Act is silent. Until the regulations or a ZIPA notice answer it, aggregation is an open point.

How long does the Zanzibar buyer permit last, and who issues it?#

The buyer provisions of the Act are silent on duration, renewal and the issuing officer, and that silence is the central finding of this piece. Paragraph 6(a) grants “resident permits”. It gives no number of years, it does not mention renewal, and it names no signatory. Section 51 and section 52 add nothing on the point. Grade, measured, as an absence in the provisions read.

What the text does supply is a front desk. The Zanzibar Investment (General) Regulations, 2025, made under section 61 and published as L.N. 59 of 2025 in the Gazette legal supplement of 20 June 2025, set up a One Stop Centre within ZIPA that includes a senior officer of the Immigration Services Department. Regulation 5 says the Centre facilitates and processes applications for work, residence, building permits and other authorisations. ZIPA is the counter. The regulations read do not say who decides or for how long.

Press and practitioner reports conflict on duration. The Guardian reported on 23 November 2023 that buyers would receive five-year residence permits. Two developer websites, in July 2024 and June 2026, report a two-year permit renewable while the buyer holds the property. The press report predates the Act’s passage on 4 December 2023, and the five-year figure sits in the paper’s own narration, between quoted remarks by the Minister of State responsible for Economy and Investment, not in a quotation. The developer reports postdate the Act and carry a commercial interest. None is primary. Grade, directional, and in conflict.

The immigration statute of the United Republic of Tanzania, the Union of which Zanzibar is part, caps a residence permit at two years and allows renewal. Section 32(2) of the Immigration Act, Cap. 54, as substituted by section 21(a) of the Written Laws (Miscellaneous Amendments) (No. 2) Act, 2024, published on 11 October 2024, says that a residence permit “may be issued for a period not exceeding two years and may be renewed”. The earlier text, three years with a total validity capped at five, no longer applies, and the new one sets no limit on renewals. The developer reports of two years renewable fit that rule, and a permit “renewable indefinitely”, as one developer page puts it, does not contradict it. The five years reported by the press predate the amendment and exceed the term of a single permit. Victaura Research read the amending Act in the Government Printer’s text. Grade, measured.

What does the Zanzibar permit leave out, work and citizenship?#

Paragraph 6(a) grants a resident permit and nothing else, so work rights and citizenship sit outside it. The paragraph mentions no employment, no work permit, no right for a dependent to work and no step toward naturalisation. The text does not forbid them in words. It never grants them. Grade, measured.

Work authorisation runs through a separate regime. A ZIPA checklist for investors, a file dated 2016 and written under the repealed 2004 investment law, says work permits are governed by the Employment Act No. 11 of 2005 and residence permits by the Immigration Act, and that a dependent pass needs the sponsor’s permits. The document is old. It still shows work and residence as different permits under different statutes. Section 54(2) of the 2023 Act adds a third route. A management company authorised to run an approved investment is to be facilitated to obtain work and residence permits. That route serves the company that runs a project, as discussed in the operator agreement guide, and on its text it does not extend to a buyer.

Citizenship is a Union matter, and property purchase appears in none of the texts read as a ground for it. In the First Schedule of the Constitution of the United Republic, as reproduced in the 2005 revision, item 6 is Citizenship and item 7 is Immigration, both Union matters. The Tanzania Citizenship Act, Cap. 357, section 9, provides for naturalisation by the Minister, on residence, language and intention conditions, and the Minister’s decision is discretionary on the 2002 consolidated text published by TanzLII. The text read lists no property ground. A Zanzibar investment Act would not be the instrument for one, which is an inference to be tested by counsel.

Marketing language blurs these lines. Online guides call the permit a golden visa or a path to a passport. Paragraph 6 contains neither idea. An allocator who needs work rights or a second nationality for a principal or a family has no basis for assuming either from this text, and that question belongs in a separate legal analysis.

What happens to the Zanzibar permit if the property is sold?#

The Act does not say what happens to the permit on sale, and no rule should be assumed. Paragraph 6 attaches the incentives to a “buyer of property”, and section 3 defines the buyer as a person who “has full ownership”. Both speak in the present tense. There is no clause on cancellation, on a grace period, on moving the permit to another unit or on the family’s permits. Grade, measured, as an absence.

The reading that the permit follows ownership is plausible and remains an inference. If a buyer is defined by present ownership, a person who no longer owns is no longer a buyer in the Act’s sense. One developer page reports that the permit is cancelled on sale, with no grace period and no automatic transfer to another property (broker-reported, June 2026). Another reports renewal while the buyer owns (broker-reported, July 2024). Neither is a legal source.

The money side of paragraph 6 anticipates an exit. Paragraph 6(d) grants one hundred percent repatriation of sales proceeds after tax. Section 34(1)(c) lets a Foreign Investor, defined as a Zanzibar company more than half foreign-owned, transfer out the proceeds on liquidation or sale of an approved investment. The Act therefore contemplates a sale. It does not say how the sale and the permit interact.

Transfer approval sits with ZIPA, and whether a resale needs it is unclear. Section 55 requires an Investor who intends to transfer or dispose of an investment, or shares or rights in it, to seek ZIPA’s written approval first. Regulations 20 and 21 set the procedure, with a twenty-four hour target for the approval letter, and they address the Approved Investor. The text read does not say that a buyer reselling a home needs the same approval. Resale liquidity, and any condition on the next buyer’s permit, are questions the project documents must answer.

Which Zanzibar thresholds are repealed, stale or unreliable?#

The Zanzibar Investment Promotion and Protection Authority Act, No. 14 of 2018 is repealed, and a threshold quoted from it is not law. Section 62(1) of the 2023 Act repeals it. The Charter Cities Institute records that the two Acts were signed on 31 December 2018 and 1 February 2024. A guide that cites the 2018 Act as the source of a property threshold cites a repealed text. Grade, measured.

A figure such as USD 300,000, which the ZIPA eRegulations page gives as a local-investor capital figure for hotel and real estate projects, is not a buyer threshold and is not in the Fifth Schedule. Paragraph 6 says one hundred thousand dollars. Victaura Research found no text, in the Act or in the contents of the 2025 regulations, that raises the buyer threshold, and this article does not use any other figure.

ZIPA’s own service pages can lag the statute. The Zanzibar eRegulations page for the ZIPA investor service, as read in October 2026, lists work and residence permits only in Classes A and B for directors, shareholders and employees, and lists no real estate buyer permit. Its local-investor capital figure for hotel and real estate projects differs from the Second Schedule of the 2023 Act. The Act is the reference.

A short rule serves the allocator, which is to take the schedule number with its date and then ask for the document. The Act has one buyer threshold, USD 100,000 on the value of the property, in paragraph 6 of Part Four of the Fifth Schedule. Section 59 lets the Minister, with the approval of the Revolutionary Council, amend or add to the Schedules on incentives, so the number can move. Any quoted figure should carry its date of reading, and this one was read on 24 October 2026.

How does Zanzibar’s buyer permit meet Tanzania’s Union immigration law?#

Immigration is a Union matter, so a Zanzibar Act can grant a permit only as far as the Union machinery honours it. The Constitution lists Immigration as item 7 of the Union matters. A Zanzibar provision that a buyer “may be granted” resident permits therefore describes an incentive whose issuing machinery sits at least partly outside Zanzibar’s own legislation. That is an inference from the allocation of powers and not a finding on practice. Grade, directional.

The Union statute vests the issuing power in an officer and classifies the permit. Under the Immigration Act, Cap. 54, Revised Edition 2016, the Commissioner General issues residence permits in Classes A, B and C. Class C goes to a person who does not qualify under A or B, if the Commissioner General thinks fit and on conditions the Commissioner General specifies. One developer page reports that the buyer permit is Class C with a sub-class designation. The sub-class number is in neither the Zanzibar Act nor the Cap. 54 text read. It is in the 2023 Union regulations, whose Second Schedule lists C-11, “Buyer of a real estate”, within Class C (Government Notice No. 428 of 2023). Grade, measured, from the text of the notice.

The 2025 regulations link the two systems through a desk. Regulation 3(2)(c) seats an Immigration Services Department officer in ZIPA’s One Stop Centre. The Citizen reported on 23 November 2023, before the Act passed, that the Minister thanked the Ministry of Home Affairs and Immigration for developing the new immigration act. On the Union side, the Immigration (Amendment) Regulations, 2023, Government Notice No. 428 of 30 June 2023, added category C-11 to Class C for buyers of real estate, on a recommendation letter from ZIPA in Zanzibar or the Tanzania Investment Centre on the Mainland and proof of a purchase value of not less than USD 100,000; PKF Tanzania’s summary gives the same conditions without the sub-class number. Victaura Research read the published notice, and it sets no term for the permit. Grade, measured.

For the allocator the layering is a diligence item. Two legal orders and two sets of officers meet at a permit whose terms the Zanzibar text leaves unwritten. The useful question for any project is which instrument carries the buyer’s permit in practice, and whether the project’s own documents warrant it. The documents to ask the seller for are ZIPA’s written approval of the project and a redacted copy of any residence permit already issued to a buyer in it, showing its class, duration and conditions.

What else does Part Four give a Zanzibar property buyer?#

“One hundred percent foreign ownership is allowed” speaks of the buyer’s nationality and says nothing on the form of title. Paragraph 6(c) says so. The Act defines land by reference to the Land Tenure Act, No. 12 of 1992, and the buyer by full ownership of real estate property. It does not describe the legal instrument over the land beneath the property. The title documents for the unit answer that, and Zanzibar counsel should read them before signing. This article does not analyse them. Grade, measured.

One hundred percent repatriation after tax is a transfer right. Paragraph 6(d) lets the sales proceeds leave after tax. It does not say which taxes, at which rates, or through which channel. Section 45 requires an investor to transact investment activities through a bank account in Zanzibar, and section 34 fixes convertible currency at the prevailing official rate for a Foreign Investor. Whether a buyer’s payment channel is the same is unstated. Grade, measured for the right, open on mechanics.

The incentives form a package that depends on project approval. If ZIPA has not approved the project, the buyer is outside the definition and none of the four incentives is available on the text. Section 35 protects investments from seizure except in the public interest, with fair and timely compensation, and section 57 provides arbitration routes between an Investor and ZIPA or the Government. Both speak of the Investor and the Approved Investment. Whether a buyer holds a protected interest under them is not stated.

What the Zanzibar buyer permit cannot tell the allocator, honestly disclosed#

The first weakness is that the Act was read in a scanned copy and not in the Gazette. The assented text came from the FAOLEX copy, and the copy published by the House of Representatives is the same assented Act, not the Bill. Victaura Research did not read the Government Printer’s copy, and a scan can omit an amending notice. Grade, measured for what was read, with a copy risk.

The second weakness is that only part of the 2025 regulations was read. Regulations 1 to 39 were read in full, with the contents list of all 49. The contents list shows no regulation headed for buyers or for approval of real estate projects. Regulations 40 to 49 and the schedules were not read for this piece, and a buyer form could sit there.

The third weakness is that the term of the buyer permit is known only as a ceiling and from reports. The class, C-11, is in Government Notice No. 428 of 2023, which sets no term, and section 32(2) of the Immigration Act, as substituted in October 2024, caps a residence permit of any class at two years and allows renewal, as the Immigration Services Department also states. Five years, and two years renewable while the buyer holds the property, come from press or developer pages, and developers have an interest in the permit looking attractive. They map what to ask for. They are not law. Grade, measured for the ceiling, directional to broker-reported for the reports.

The fourth weakness is that nothing here says any given project qualifies. This article does not state whether any scheme, including Victaura’s Secret Zanzibar Hotel & Villas, which is in active development, is an approved real estate project for the purpose of the permit. The project page is the public reference, and approval is a fact for ZIPA to certify. The principal should ask any seller for ZIPA’s written approval of the project.

The reading, in one line, is that Zanzibar legislated a permit incentive and left its terms to documents not yet in the public text. The threshold, the family scope and three companion incentives are in the Act. Duration, renewal, issuer and the effect of a sale are not. The allocator’s position is to value the permit at what the text states, a permit that “may be granted”, and to treat the rest as unverified until documented.

Skin in the game disclosure. Victaura, through its parent Greystone B.V. (Netherlands), develops projects on Lake Como (Italy), in Nungwi, Zanzibar (Tanzania), on Gili Air and in Uluwatu, Bali (Indonesia), and holds an off-plan capital position on Al Marjan Island, Ras Al Khaimah (UAE). Readers should assume commentary may be influenced by, or benefit, these positions. This document is classified as marketing material under MiFID II Article 24(3). It is not investment advice.