Gibraltar's headline corporate income tax (CIT) rate is 15% (from 1 July 2024; 12.5% prior; 20% for utilities/dominant-position companies).
The headline personal income tax (PIT) rate is 14-39% (allowances system) or 6-28% (gross income system), 25% effective cap.
0% - Gibraltar has no VAT.
An individual is generally ordinarily resident if present in Gibraltar for 183 days in a year of assessment, or more than 300 days across three consecutive years, confirmed via a specialist tax source. There is no separate legal concept of "residence" distinguished from "ordinary residence" under Gibraltar law, confirmed via Chambers and Partners. Companies are taxed on a territorial basis: income accruing in or derived from Gibraltar is taxable, and companies generating profits entirely outside Gibraltar are not subject to Gibraltar corporate tax, confirmed via a specialist source. Partnerships (general, limited, and LLPs) are tax-transparent regardless of any separate legal personality elected under the Limited Partnerships Act 2021 - residence is applied to the individual partners, not the partnership itself.
Confirmed directly and consistently via two independent, detailed sources: Gibraltar does have Controlled Foreign Company rules, transposed from the EU's Anti-Tax Avoidance Directive (ATAD) even post-Brexit, confirmed via Chambers and Partners. Specific mechanics, confirmed via ICLG's Private Client guide: the rules attribute to a Gibraltar company the undistributed profits of a CFC arising from non-genuine arrangements put in place for the essential purpose of obtaining a tax advantage. Gibraltar separately has "transfer of assets abroad" legislation enabling tax authorities to assess offshore-structure income against Gibraltar-ordinarily-resident persons in certain circumstances - a related but distinct anti-avoidance mechanism from the CFC rules themselves.
Gibraltar has interest deductibility restrictions in place rather than a conventional debt-to-equity thin capitalization ratio, confirmed via Chambers and Partners; specific numeric parameters were not itemized in sources reviewed this session. Gibraltar's tax system is described as "hybrid" - largely territorial but incorporating CFC and other anti-avoidance measures to accommodate both domestic goals and international standards (OECD/EU), confirmed via the same source.
No domestic FBAR/Form 8938-equivalent requiring Gibraltar residents to self-report their own foreign accounts was identified. Gibraltar has entered into exchange-of-information agreements pursuant to OECD requirements, confirmed via ICLG. Separately and independently of local law, US citizens and Green Card holders with Gibraltar accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of local requirements.
Gibraltar and the UK signed a new income tax treaty in October 2019, which came into force in April 2020 and is now fully in force, confirmed directly via ICLG - since Gibraltar has no capital gains tax, the treaty does not cover capital gains specifically. Gibraltar has a strengthened General Anti-Avoidance Rule (GAAR) introduced through 2024 amendments to the Income Tax Act, targeting "artificial and fictitious" transactions and referencing consistency with OECD Transfer Pricing Guidelines, confirmed via Chambers and Partners. A comprehensive named-partner list beyond the UK treaty was not compiled this session.