Gibraltar operates a territorial basis of taxation: only income accruing in or derived from activities carried out within Gibraltar is subject to corporate income tax, and foreign-source income (including commercial revenue from operations conducted wholly outside Gibraltar) is generally exempt, with limited exceptions for royalty income and related-party interest income exceeding GBP 100,000. The standard corporate income tax rate is 15% (increased from 12.5% effective July 1, 2024), administered by the Income Tax Office.
The tax year generally follows the company's own accounting period; individuals are assessed on the year of assessment running to the following June, with residence tested against the current and two preceding years for the alternative 300-day rule.
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. There is no separate legal concept of "residence" distinguished from "ordinary residence" under Gibraltar law. 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. 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.
A non-resident company is taxed on profits attributable to activities carried on in Gibraltar through a permanent establishment. Because Gibraltar's system is territorial, a resident company that is centrally managed and controlled in Gibraltar, or a foreign company operating through a Gibraltar permanent establishment, is taxed only on Gibraltar-source and Gibraltar-derived profits rather than on worldwide income.
Gibraltar does have Controlled Foreign Company rules, transposed from the EU's Anti-Tax Avoidance Directive (ATAD) even post-Brexit. A foreign entity or permanent establishment is a CFC where a Gibraltar taxpayer, alone or with associated enterprises, holds more than 50% of the voting rights, capital, or profit entitlement, and the entity's actual foreign tax paid is less than half of what Gibraltar tax would have been on the same profits. Only non-distributed income arising from non-genuine arrangements set up primarily to obtain a tax advantage is attributed back to the Gibraltar taxpayer, and small entities are carved out entirely (no more than EUR 750,000 in accounting profits, or non-trading income no more than EUR 75,000, or profits no more than 10% of operating costs). 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. 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).
Gibraltar classifies entities under its own domestic Income Tax Act rather than offering an elective check-the-box system. Gibraltar has transposed CFC rules from the EU's Anti-Tax Avoidance Directive even post-Brexit: the non-distributed income of a foreign entity or permanent establishment may be attributed to a Gibraltar taxpayer holding more than 50% of its voting rights, capital, or profit entitlement where the arrangement is non-genuine and primarily tax-motivated, with a de minimis carve-out for entities with EUR 750,000 or less in trading profits and EUR 75,000 or less in non-trading income, or where profit does not exceed 10% of operating costs.
No domestic FBAR-equivalent regime requires Gibraltar residents to separately disclose foreign financial accounts. Gibraltar is a CRS participating jurisdiction and exchanges financial account information with partner tax authorities, including the UK. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of Gibraltar's own rules.
Dividends received by a Gibraltar company from another company are exempt from tax, functioning as a broad participation exemption without the minimum-holding-period or ownership-percentage thresholds common in other jurisdictions' regimes; local expenses attributable to exempt foreign-source income are correspondingly non-deductible.
No dedicated unilateral foreign tax credit provision is identified, consistent with Gibraltar's territorial system generally exempting foreign-source income outright rather than taxing it and then crediting foreign tax paid; relief from double taxation for the more limited categories of foreign income that are taxable in Gibraltar (such as certain royalty and related-party interest income) depends primarily on the Gibraltar-UK income tax treaty in force since April 2020.
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. 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. A comprehensive named-partner list beyond the UK treaty is not compiled in available sources for this page.