New Caledonia

A resident company is subject to corporate income tax (so-called ‘corporate income tax on companies and metallurgical or mining activities’; CIT) in New Caledonia on its New Caledonian-source income (deriving from an activity performed in New Caledonia or entities having their head office in New Caledonia). Taxable income in New Caledonia could also results from the application of a double tax treaty (DTT) between New Caledonia and another country.

New Caledonia levies CIT at a 35% rate for metallurgical or mining activities. For other corporates, CIT is levied at a 30% rate (that could be reduced to 15% depending on turnover thresholds). Even though the government has announced its wish to progressively reduce the standard CIT rate, no law has been enacted in this regard.

Additional contribution on corporate income tax (CAIS)

The CAIS (contribution additonnelle à l’impôt sur les sociétés) applies at a 3% rate to the income distributed (or deemed distributed) by corporations or entities subject to the CIT whenever the amount of the income distributed during a fiscal year exceeds XPF 30 million.

Additional Social Contribution (CSA)

The Additional Social Contribution (Contribution Sociale Additionnelle) applies, at a progressive tax rate from 5% to 15% (depending on the profits), to legal entities subject to the CIT and whose taxable income at the standard rate (30%) reaches or exceeds XPF 200 million. This contribution is not deductible from the taxable income for CIT.

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 the 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, and 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 levied, at a rate ranging from 2% to 4%, notably on the income from securities for natural or legal persons subject to the IRVM, and on the private real estate capital gains for those subject to the tax on private real estate capital gains (PVI).