New Caledonia

CIT rates on branch profits are the same as on corporate profits. As a principle, branch profits are deemed to be distributed to the head office.

Deemed distributed income are also subject to IRVM at a 10% rate, CCS at a 5% rate, and to centimes additionnels (communal tax), and the CAIS at a 3% rate would also apply, depending on the deemed distributed profits amount.

In a judgment of 29 December 2023, the Council of State stated that the DTT concluded between France and New Caledonia provides that the profits made by a permanent establishment (PE) in New Caledonia cannot, after having borne the CIT, be subject to a tax whose rate exceeds 10%. This judgment directly targets the case of taxpayers submitting income earned through a PE in New Caledonia to both the IRVM and the CAIS.