Fiji taxes resident individuals and companies on worldwide income, with non-residents taxed only on Fiji-source income, generally collected via withholding tax. The standard corporate income tax rate is 25% (increased from 20% effective January 1, 2023), administered by the Fiji Revenue and Customs Service (FRCS); companies listed on the South Pacific Stock Exchange with at least 40% resident shareholding qualify for a reduced 15% rate for 7 years from listing.
The tax year generally follows the calendar year for individuals; companies may adopt an approved accounting period. Group taxation is not permitted in Fiji, so each company within a corporate group files and is assessed separately.
25% standard rate.
Progressive up to 20%.
15% standard VAT (Fiji Revenue & Customs Service; some older sources still cite a superseded 12.5% rate - use the current 15% figure).
An individual is a Fiji tax resident if domiciled in Fiji, or present in Fiji 183 days or more within a 12-month period (one secondary source alternatively describes a permanent-home-plus-30-days test, which may reflect a specific statutory alternative route rather than a conflict - confirm exact wording with the Fiji Revenue & Customs Service (FRCS) for precision). Residents are taxed on worldwide income; non-residents only on Fiji-source income, generally via withholding.
A non-resident enterprise is subject to Fiji corporate tax where it carries on business through a permanent establishment in Fiji, understood as a fixed place of business or a dependent agent, consistent with treaty-based PE definitions used in Fiji's roughly 5 to 7 double tax agreements. Payments to non-residents without a Fiji permanent establishment are instead collected through non-resident withholding tax on dividends, interest, royalties, management fees, and know-how payments.
Fiji has no Controlled Foreign Company rules, per KPMG's Fiji tax profile.
Under the Income Tax Act 2015, a genuine thin capitalization rule applies: where a foreign-controlled resident company (other than a financial institution) exceeds a 2:1 debt-to-equity ratio during a tax year, interest paid on the excess debt is non-deductible - unless the excess debt does not exceed "arm's length debt" (i.e., the amount an independent lender would have extended on similar terms). Fiji also has General Anti-Avoidance Rules (GAAR) as FRCS's primary mechanism for challenging avoidance schemes, and anti-treaty-shopping provisions are embedded in a number of Fiji's tax treaties.
Fiji classifies entities under its own domestic Income Tax Act 2015 rather than offering an elective check-the-box system, and no ATAD2-style anti-hybrid mismatch regime addressing double-deduction or deduction-without-inclusion outcomes has been identified. Fiji has no CFC rules, but does apply a 2:1 debt-to-equity thin capitalization test to foreign-controlled resident companies and maintains General Anti-Avoidance Rules (GAAR) as its primary mechanism for challenging artificial cross-border arrangements.
No domestic FBAR-equivalent regime requires Fiji residents to separately disclose foreign financial accounts, and Fiji's CRS participation status is not confirmed in accessible sources, meaning it may not automatically exchange financial account information with foreign tax authorities under the OECD's Common Reporting Standard; confirm current status directly with the Fiji Revenue and Customs Service before relying on this page. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of Fiji's own rules.
No dedicated participation exemption regime for dividends or capital gains from a qualifying subsidiary was identified. Fiji instead operates a qualifying dividend tax credit system: company tax already paid generates credits that can be attached to dividends paid to shareholders, which non-resident shareholders can use to reduce the non-resident dividend withholding tax otherwise due, functioning as an imputation mechanism rather than a conventional exemption.
Fiji allows a foreign tax credit for tax paid in another country on foreign-source income, limited to the lesser of the Fiji tax or the overseas tax otherwise payable on that same income, available on a unilateral basis in addition to relief available under Fiji's bilateral tax treaties.
Sources place Fiji's treaty network between 5 and 7 countries depending on the count method, with Australia, New Zealand, and the UK confirmed as key partners across multiple sources. Fiji has no comprehensive double tax agreement with the United States or Germany. Fiji allows unilateral double-tax relief on income from non-treaty countries provided that income was already taxed there, and also participates in regional trade frameworks (PICTA, PACER Plus) that are separate from its bilateral tax treaty network.