French overseas collectivity in the South Pacific with a genuinely distinct fiscal system - zero personal taxation alongside a conventional corporate tax.
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 was confirmed from a primary source this session, consistent with the limited practical relevance of individual residency given the absence of a personal income tax.
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.
No domestic FBAR/Form 8938-equivalent requiring French Polynesia residents to self-report their own foreign accounts was identified. One lower-quality source claims French Polynesia "participates in CRS via France," but this should be treated with caution rather than assumed accurate - as confirmed by PwC's France corporate residence guidance (see Treaty Network below), French Polynesia is one of France's "overseas territories" with an autonomous tax regime treated as foreign for French tax-territoriality purposes, so its institutional CRS/FATCA participation should not be assumed to automatically mirror metropolitan France's without direct confirmation. Separately and independently of local law, US citizens and Green Card holders with French Polynesia accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of French Polynesia's own domestic requirements.
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 already confirmed for New Caledonia this session, 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.