New Caledonia

There is no tax group regime in New Caledonia. See Dividend income in the Income determination section for more information on the preferential regime of dividends distributions between related entities.

Transfer pricing

Profits indirectly transferred outside New Caledonia, either by increasing or decreasing purchase or sale prices or by any other means, are incorporated into the results recorded by the accounts.

When, during a tax audit, the tax services department has gathered elements leading to the presumption that a company has made an indirect transfer of profits, it may request this company information and documents specifying:

• The method of determining the prices of operations carried out with companies or groups established outside New Caledonia and the elements that justify it, as well as, where applicable, the compensation granted.
• Activities carried out by companies or groups established outside New Caledonia.
• The tax treatment of operations carried out by the companies outside New Caledonia or by the companies or groups of which it holds, directly or indirectly, the majority of the capital or voting rights.

Thin capitalisation

There are no specific thin capitalisation rules in New Caledonia. Please see Interest expenses in the Deductions section.