Tanzania's Government Notice No. 487A of 2025 reserves fifteen categories of business activity for citizens. Much of the early commentary has treated the Order as imprecise — principally because it defines "non-citizen" by reference to the Citizenship Act (Cap. 357), which does not itself define the term and applies only to natural persons.
This Lyson Law commentary offers a different reading. It argues that the definitional gap is deliberate: an anti-circumvention measure designed so that attempts to evade the Order through corporate structuring fall to be determined by the courts under the mischief rule, rather than resolved administratively by BRELA at the point of registration. The analysis distinguishes the sophistication of the drafting from the bluntness of its current implementation, and proposes measured steps toward clarification.
