New Caledonia

Specific tax credit applicable to mining or metallurgical activities

Mining companies may benefit from various tax incentives for mining or metallurgical investments projects in New Caledonia.

Companies carrying out these activities are subject to CIT at a rate of 35%. However, they are benefiting from specific incentives, such as:

• Tax stabilisation regime (régime de stabilisation fiscale) by which companies benefit from a stability, during a 15-years period, when it comes notably to tax rates, tax base, and applicable taxes.
• Restricted carryback of tax losses regime.
• Dividends distribution regime to certain French shareholders.

Tax credit for research and development (R&D)

The R&D tax credit is determined on the basis of the eligible R&D expenses incurred during the calendar year.

The R&D tax credit is determined on the basis of R&D projects qualified as eligible and is equal to 30% of the sum of qualifying R&D expenses (until December 2024). The R&D tax credit is capped at XPF 5 million.

Tax reduction on charitable donations

For charitable donations, the tax reduction amounts to 60% of the amount of the payments. For the calculation of the reduction, the amount of the payments is taken into account within the limit of 5 per thousand of turnover.

Donations and charitable contributions are not deductible for CIT purposes. The tax reduction on charitable donation can be offset against the CIT liability payable by the taxpayer with respect to the financial year during which the donations were granted.

Loans for acquisition of principal residence

Credit institutions (as defined by Art.  511-1 of monetary and financial French Code) liable to CIT in New Caledonia may benefit from a tax credit for repayable advances not bearing interest, issued between 1 January 2011 and 31 December 2030 and granted to individuals subject to resource conditions, for the acquisition or construction of a main residence located in New Caledonia as a first property purchase and paid during the tax year or financial year.

The amount of the tax credit is equal to the discounted sum of the differences between the monthly payments due for the interest-free repayable advance and the monthly payments of a loan granted under normal rate conditions on the date of issue of the tax credit.

Foreign tax credit

Under the DTT signed between New Caledonia and France, several methods have been established to avoid double taxation depending on the revenues:  deduction of a tax credit from tax effectively paid, a tax exemption, or the exclusive right to tax.