A self-governing state in free association with New Zealand. PwC's Worldwide Tax Summaries lists the Cook Islands (together with Niue) among New Zealand's associated 'privileged taxation jurisdictions.'
20% standard rate for resident domestic companies (worldwide income); 28% for non-resident domestic companies, taxed only on Cook Islands-source business profits. International Companies (offshore entities not conducting local business) lost their statutory tax exemption under a 2019 amendment, phased in for existing companies from January 1, 2022.
Progressive: exempt up to NZD 10,000 (full-year residents only, apportioned for partial-year residents), 25% from NZD 10,001 to 30,000, and 30% above NZD 30,000. Non-residents face a different bracket structure starting at 20% with no exemption.
15% standard rate, confirmed via the Cook Islands Revenue Management Division's own published guidance. Applies to goods and services supplied in the Cook Islands and to imported goods and certain imported services; registration threshold is NZD 40,000 for non-resident digital service providers.
Individual residency is generally triggered by physical presence exceeding 183 days in a calendar year (OECD-reported test). A company is deemed Cook Islands tax resident if incorporated there, or if its directors, acting as directors, exercise control of the company within the Cook Islands - even if some of that decision-making also occurs elsewhere. Resident companies are taxed on worldwide income; non-residents only on Cook Islands-source income.
The Cook Islands has no domestic CFC regime of its own. This is separate from - and does not override - CFC rules that may exist in a beneficial owner's home jurisdiction (for example, US Subpart F/GILTI or another country's CFC attribution regime), which can still tax a foreign owner on Cook Islands entity income regardless of the Cook Islands' own lack of a CFC regime.
No dedicated statutory thin capitalization ratio was identified in available sources for the Cook Islands. This is flagged as a genuine gap after a real search effort, not a confirmed absence of any interest-deductibility limit.
No domestic FBAR/Form 8938-equivalent requiring Cook Islands residents to self-report their own foreign accounts was identified. The Cook Islands participates in international tax information exchange - it has concluded Tax Information Exchange Agreements (TIEAs) with New Zealand, Australia, and other partners, generally limited to information sharing on specific request rather than automatic exchange - and is subject to enhanced international AML/CFT monitoring (FATF grey list) as of the sources reviewed, which affects banking due diligence rather than personal tax self-reporting. Separately and independently of Cook Islands law, US citizens and Green Card holders with Cook Islands accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of Cook Islands domestic requirements.
Very narrow: the Cook Islands does not maintain a broad network of comprehensive double tax agreements. One source identifies 2 double tax agreements (New Zealand and Australia) alongside a small number of additional TIEAs, for roughly 4 total information-sharing instruments; another source states plainly that the Cook Islands has no DTA network at all beyond favorable treatment for non-residents. Given this discrepancy, treat the exact DTA count as unconfirmed and verify current treaty status directly with the Cook Islands government before relying on treaty relief.