French overseas collectivity in the South Pacific with a genuinely distinct fiscal system - zero personal taxation alongside a conventional corporate tax.
French Polynesia, a French overseas collectivity, operates a genuinely distinct fiscal system from mainland France: it levies no personal income tax, no wealth tax, and no inheritance or gift tax between residents, while applying a conventional corporate tax on companies operating in the territory. The standard corporate tax rate is 25%, with a reduced 20% rate for renewable energy production and a higher 35% rate for financial and credit institutions and leasing companies.
The tax year generally follows the calendar year for corporate filings; individuals face no annual income tax filing obligation given the absence of a personal income tax, though the Territorial Solidarity Contribution (CST) withheld from wages and distributed profits is collected at source by the employer or payer throughout the year.
25% standard rate (20% for renewable energy production; 33% for mining, financial institutions, and leasing companies, scheduled to decline gradually to 25% by 2027).
0% - French Polynesia does not levy personal income tax on individuals, confirmed by International Labour Organization statistical methodology for the territory; also 0% wealth tax and 0% inheritance/gift tax between residents.
0% - no VAT or general sales tax; the territory relies on corporate tax and social contributions instead.
French Polynesia operates a territorial tax system - the operative question is where income is sourced, not worldwide residency status, which matters less here given the 0% personal income tax rate. A resident company is generally one incorporated or operating under French Polynesia's local commercial framework; non-residents are subject to withholding tax on French Polynesia-source income (dividends, interest, royalties, technical and management service fees). No specific statutory day-count test for individuals is identified in accessible sources, consistent with the limited practical relevance of individual residency given the absence of a personal income tax.
Profits made in French Polynesia by a company whose head office is located outside the territory, but which owns or operates local property or performs taxable operations there, are deemed distributed to non-resident associates and become subject to the tax on income from movable capital (impot sur le revenu des capitaux mobiliers) in proportion to the company's activity within French Polynesia; this deemed-distribution mechanism functions as French Polynesia's practical permanent establishment rule for non-resident corporate activity, subject to a specific carve-out under the 1957 agreement between the French Government and the territory for companies headquartered in Metropolitan France.
No Controlled Foreign Company regime was identified in available sources for French Polynesia.
No statutory thin capitalization ratio or interest-limitation rule was identified in available sources for French Polynesia specifically.
French Polynesia classifies entities under its own local commercial and tax framework rather than offering an elective check-the-box system, and as an overseas collectivity with an autonomous tax regime treated as a foreign territory for French corporation tax purposes, it is not automatically bound by mainland France's own CFC rules or France's implementation of the EU Anti-Tax Avoidance Directive's anti-hybrid provisions; no dedicated French Polynesia anti-hybrid mismatch regime has been identified, and French anti-hybrid rules should not be assumed to extend to the territory.
No domestic FBAR-equivalent regime requires French Polynesia residents to separately disclose foreign financial accounts. French Polynesia participates in the OECD Common Reporting Standard (CRS), meaning tax residency status is reported to foreign tax authorities for residents holding accounts abroad, notwithstanding the territory's autonomous tax regime on income taxes themselves. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of French Polynesia's own rules.
No dedicated participation exemption regime for dividends or capital gains from a qualifying subsidiary was identified; French Polynesia's territorial approach instead taxes distributions and movable-capital income through the tax on income from movable assets and the associated 5% Territorial Solidarity Contribution described above, rather than through a distinct minimum-ownership exemption.
French Polynesia's own tax code does address unilateral and treaty-based methods for relief from double taxation (per Orbitax's Country Chapter for French Polynesia), though the specific mechanics were not fully confirmed. Separately, the UK's own HMRC Double Taxation Relief Manual confirms specific French Polynesian taxes (corporation tax, territorial solidarity tax, extraordinary solidarity tax) as admissible for UK unilateral relief - useful context, though this describes UK-side relief for tax paid in French Polynesia rather than French Polynesia's own domestic credit mechanism. As established elsewhere on this page, French Polynesia's only confirmed tax treaty is with France itself; relief involving non-French counterparties should not be assumed available through France's broader treaty network, which generally excludes the overseas territories.
A genuine and important correction to a claim found in lower-quality sources: one source asserts French Polynesia residents benefit from "France's 120+ DTAs including comprehensive treaties with the US, UK, Germany, Canada, Switzerland." This is very likely inaccurate. PwC's authoritative France corporate-residence page explicitly states that France's "overseas territories" - named as New Caledonia, French Polynesia, Wallis and Futuna, Saint Pierre et Miquelon, and French Southern and Antarctic Lands - "have autonomous tax regimes and are therefore treated as foreign territories for the purposes of the territoriality rules applicable to corporation tax." This is the identical structural pattern documented on this site's New Caledonia page, where PwC directly confirms only one treaty exists (with France itself) and that most French bilateral treaties with other countries explicitly exclude the overseas territories from their scope. Given this, treat the "120+ DTA" claim for French Polynesia as unverified and likely wrong pending direct confirmation, rather than repeating it as fact.