New Caledonia

Social security contributions

The New Caledonian social security system is composed of various schemes providing a wide range of benefits. This system includes social security basic coverage, unemployment benefits, complementary retirement plans, death/disability coverage, and complementary health coverage. The contributions are based on the remunerations, and monthly thresholds are applicable to determine the rate, which ranges from 0.2% to 11.67%.

Capital gains taxes

Capital gains derived by individuals are generally not taxable. However, the New Caledonian government has recently implemented a taxation on capital gain deriving from real properties.

The tax on private real estate capital gains (PVI) is a tax due when an individual or a partnership (e.g. an SCI) sells real estate, as long as this property has experienced an increase in value between its date of acquisition and that of its transfer. This tax is 20% of the amount of the capital gain, to which must be added 4% of the CCS, or 24% in total. There are a number of exemptions and special rules for calculating the amount of tax.

General consumption tax (TGC)

The TGC (taxe Générale sur la consummation) is a value-added tax (VAT)-like tax that is applied to the consumer prices of goods and services since 1 October 2018 in New Caledonia.

TGC is due on goods sold and services rendered in New Caledonia. There are four rates of TGC:

• Reduced rate: 3%
• Specific rate: 6%
• Normal rate: 11% for all the operations that are not subject to another rate.
• Higher rate: 22%

Supplies of goods outside New Caledonia and certain specific services invoiced to foreign clients are, in principle, exempt from TGC.

Some transactions are TGC exempted, such as:

• Exemptions of transactions for reasons of public interest.
• Some transactions in relation with real property
• Some transactions subject to other taxation, such as insurance premiums tax, tax on financial operations, etc.

Net wealth/worth taxes

There is no net wealth tax.

Inheritance, estate, and gift taxes

New Caledonian inheritance or gift tax may be due by beneficiaries of gifts or inheritance. If the deceased or the donor is a tax resident of New Caledonia, tax will be due in New Caldonia on worldwide assets transmitted. If the deceased or donor is not a tax resident of New Caldonia, tax will be due on new Caledonian assets transmitted.

Inheritance tax is levied on assets at their fair market value, with allowances taking into account the relationship between the deceased and the beneficiary. Debts existing at the time of death are generally deductible in full.

No inheritance tax is due for inheritance between spouses (or partner of a Pacte civil de solidarité [PACS]) and for inheritance between brothers and sisters living together under specific conditions.

Progressive tax rates (ranging from 5% to 20%) are applicable after a rebate of XPF 100,000 when beneficiaries are direct dependants (spouse or partner of a PACS).

Between non-related parties or non-direct dependants (siblings), the rate is ranging from 30% to 50%.

Life insurance contract are benefiting from a preferential tax regime when premiums has been paid by the deceased before they are 70.

Gift tax is subject to the same standard rules, but some differences could exist.

Property taxes

The real estate tax is a tax established on the ownership of land and buildings, which varies according to the municipalities, neighborhoods, and type of construction.

Real estate property tax is levied on:

• land
• constructions, including fixed, and
• industrial equipment and tools.

The principal tax is obtained by successively multiplying the surface area of the land or construction (gross surface area) by the rate per area or m2 (to determine the tax base) then, by the rate of 8.40% for buildings and 0.7875% for land.

Business licence duty

Taxation of the business license (contribution des patentes) is compulsory for any natural or legal person who undertakes in New Caledonia the exercise of a trade, an industry, or a profession, for their own account and for profit.

It is calculated annually depending on the type and characteristics of the professional activity and is made up of a fixed fee (composed of a fixed tariff and additional tariffs) and a proportional duty (based on customs). If a company carries out its activity through several establishments, it will have to pay as many licences as it has establishments.