New Caledonia benefits from tax autonomy from France: its Congress adopts its own tax laws, gathered in a local tax code (the New Caledonia Tax Code, NCTC), administered by New Caledonia's own tax authority rather than the French tax administration. A resident company is subject to corporate income tax on New Caledonia-source income (activity performed in New Caledonia or head office located there), consistent with the territorial approach also described in the Residency section of this page.
The tax year generally follows the company's accounting period; a distinct annual tax on distributed income (IRVM, 11.5% theoretical rate) applies separately to dividends and other distributed income from CIT-paying entities, and an 8% tax (IRCDC) applies to interest and similar debt-based income.
New Caledonia's headline corporate income tax (CIT) rate is 30%.
The headline personal income tax (PIT) rate is 40%.
The standard VAT/GST (or equivalent consumption tax) rate is 11% (TGC).
An individual is domiciled in New Caledonia (and thus generally taxed on worldwide income) if any of the following applies: the habitual abode of the person or family is in New Caledonia or it is their principal place of sojourn, professional activities are carried out in New Caledonia, or New Caledonia is the center of their economic interests. Under the bilateral tax treaty between France and New Caledonia, tax domicile is determined first under the law of the country asserting the power to tax. A separate secondary source states the domestic-law threshold as 183 or more days of physical presence in the tax year - broadly consistent with the "principal place of sojourn" test above, though the exact statutory wording should be confirmed against the New Caledonia Tax Code (NCTC) directly. Non-domiciled individuals are taxed only on New Caledonia-source income. A resident company is subject to CIT on its New Caledonia-source income (activity performed in New Caledonia or head office located there).
A non-resident company or individual carrying on activity in New Caledonia is brought within New Caledonia's tax net where that activity is performed in New Caledonia or through a locally-headquartered entity; New Caledonia's territorial system means the operative question for a foreign enterprise is where the activity is actually carried out rather than a codified fixed-place-of-business test comparable to a full OECD Model PE article, since New Caledonia's only comprehensive tax treaty is with France itself.
New Caledonia has no CFC regime. Anti-avoidance is instead handled through a transfer-pricing-style provision addressing profits indirectly transferred outside New Caledonia via price manipulation or other means, which are added back into taxable results - this is a transfer pricing rule, not a CFC attribution regime.
There are no specific thin capitalization rules in New Caledonia.
New Caledonia classifies entities under its own local tax code 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, consistent with New Caledonia having no CFC regime of its own. There is no tax group (fiscal consolidation) regime in New Caledonia; profits indirectly transferred outside New Caledonia through manipulated purchase or sale prices, or by any other means, are added back into the local entity's taxable results as New Caledonia's principal base-erosion safeguard.
No domestic FBAR-equivalent regime requires New Caledonia residents to separately disclose foreign financial accounts. New Caledonia is a CRS participating jurisdiction and exchanges financial account information with partner tax authorities. US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of New Caledonia's own rules.
New Caledonia applies a preferential regime to dividend distributions between related entities, reducing the effective burden of the IRVM tax on qualifying intercompany dividends; PwC's New Caledonia corporate tax summary confirms the regime exists but does not publish a specific numeric ownership threshold or holding-period condition. Confirm current conditions directly with the New Caledonia tax administration (Direction des Services Fiscaux) before relying on this page.
Foreign-source income is not subject to New Caledonia income tax where the taxpayer can demonstrate that the income is already subject to a similar income tax in the source state, a unilateral exemption-style relief mechanism rather than a conventional foreign tax credit; where a New Caledonia tax treaty specifically excludes certain foreign-source income (as with France under the sole comprehensive treaty in force), that treaty exclusion controls instead.
Very narrow and a point of frequent confusion that this page specifically avoids repeating: New Caledonia has entered into only one comprehensive tax treaty, with France itself. It is not a sovereign state and does not independently benefit from France's broader bilateral treaty network - most French tax treaties with other countries explicitly exclude New Caledonia from their territorial scope. New Caledonia has no double tax agreement with the United States. Residents rely on domestic unilateral relief provisions (administered by the Direction des Services Fiscaux, DSF) for other cross-border income situations rather than treaty relief - New Caledonia's domestic law does not tax foreign-source income where the taxpayer can demonstrate it was already subject to a similar income tax in the source country.