New Caledonia

Individuals, whether New Caledonian or foreign nationals, who have their tax domicile in New Caledonia are generally subject to personal income tax (PIT) on worldwide income (unless provided otherwise by a tax treaty between France and New Caledonia). Individuals who are not domiciled in New Caledonia (non-residents) are generally subject to tax only on their income arising in New Caledonia.

Personal income tax rates

Resident individuals

Each category of income is combined and, after deduction of allowances, is taxed at progressive rates. Total income is split according to family status (i.e. 'the more children you have, the less tax you pay’). Under income-splitting rules, total taxable income is divided by the number of shares awarded to the taxpayer: generally one share for a single person, two shares for a married taxpayer without children, one share and a half for a widow with dependent children, half a share for each dependent child, and one full share for handicapped children or children studying abroad.

However, the tax saved from income splitting is generally limited to XPF 300,000.

For residents, progressive income tax rates are then applied as follows:

Certain corrections must be made afterwards in order to determine the net tax liability. For instance, the tax credits must be applied as well as any foreign tax credits.

Non-resident individuals

Generally, income derived by non-resident individuals is subject to a flat tax rate (prélèvement forfaitaire) of 25%. This tax applies to very broad types of revenues, notably employment and business or professional related income, pensions, investment income (unless subject to tax on financial incomes [IRVM]), royalties, and income from immovable property.

A taxpayer is allowed to claim for the application of the progressive tax rate (as for resident) if one is in position to demonstrate that the progressive PIT would have been less than 25%.

Tax on financial incomes (IRVM)

The IRVM (impôt sur le revenue des valeurs mobilières) applies, at a theoretical rate of 11.5%, to the income distributed (or deemed distributed) by companies or entities subject to CIT in New Caledonia.

IRVM is due on all incomes distributed mentioned in Article Lp. 529 of local tax code (e.g. dividends, interest). Some entities are expressly exempted from IRVM.

Income tax on debts, deposits, and guarantees (IRCDC)

The IRCDC (impôt sur le revenue des créances, dépôt et cautionnements) applies at 8% on interest, arrears, mortgage, privileged and unsecured debts having the characteristic of a money loan, cash guarantees, associates' current accounts, deposits of sums of money, on demand or with fixed maturity, whatever the depositary and whatever the use of the deposit (bonds, capitalisation contracts, etc.) There are exemptions provided by Art. Lp. 555 of the local tax code.   

Caledonian solidarity contribution (CCS)

The CCS is applicable to various kinds of income. It applies on securities products for natural or legal persons subject to the IRVM, on savings products for those subject to the tax on income from debts, deposits, and guarantees (IRCDC), on gaming proceeds for those subject to the tax on gaming proceeds, and on private real estate capital gains for those subject to the tax on private real estate capital gains (PVI).

The CCS rates are as follows:

• For earned income (revenus d’activité): 2% from 1 July 2022.
• For replacement and solidarity income: 1.3% from 1 October 2021.
• For income of assets: 4% from 1 January 2023.
• For savings and investment products: 4% from 1 July 2022.
• For gaming products: 4% from 1 July 2022.
• For securities products: 4% from 1 July 2022.
• For private real estate capital gains: 4% from 12 December 2023.