A self-governing state in free association with New Zealand. PwC's Worldwide Tax Summaries lists Niue (together with the Cook Islands) among New Zealand's associated 'privileged taxation jurisdictions.'
30% flat rate on Niue-source income, applying equally to resident and non-resident companies under Niue's territorial system - income sourced outside Niue is generally not subject to Niuean tax. International Business Companies formed under the International Business Companies Act 1994 pay no tax in Niue and no tax on offshore profits, instead paying a low flat annual government fee.
Progressive up to 30%, administered under the Income Tax Act 1961 (as amended, most recently consolidated in a 2019 reprint). A Taxpayer Identification Number (TIN) issued by the Niue Tax Administration Office is required for individuals, companies, non-profits, and trusts to open a bank account, receive salary, declare income, or hold a business license.
12.5% Niue Consumption Tax (NCT), modeled directly on the New Zealand GST. Introduced revenue was partially offset at the time by lowering income tax, import taxes, and secondary-income tax rates. Per OECD Revenue Statistics, VAT/GST was Niue's largest single tax revenue category (42.8% of tax revenue in 2023).
Niue applies a territorial system where the operative question is the source of income rather than residency status alone - both residents and non-residents are taxed principally on Niue-source income, with the practical effect that "where do you live" matters less than "where does this income come from." No specific statutory day-count residency test was confirmed from a primary source this session; individual and entity tax obligations attach through TIN registration with the Tax Administration Office rather than a pure presence test.
No Controlled Foreign Company regime was identified in available sources for Niue.
No statutory thin capitalization ratio or interest-limitation rule was identified in available sources for Niue itself. Note this is distinct from New Zealand's own "outbound" thin capitalization rules, which apply to New Zealand residents holding CFC or FIF interests (potentially including Niue entities) rather than to Niue's domestic tax base.
No domestic FBAR/Form 8938-equivalent requiring Niue residents to self-report their own foreign accounts was identified. Niue is a signatory to the Common Reporting Standard (CRS) and has financial information exchange agreements with multiple countries, indicating institutional-level participation in automatic exchange. Separately and independently of Niue law, US citizens and Green Card holders with Niue accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of Niue's own domestic requirements.
Niue does not maintain a broad network of comprehensive double tax agreements. It does hold a Tax Information Exchange Agreement (TIEA) with New Zealand (confirmed via New Zealand's own GSL-sourced treaty list, which names Niue among its 18 TIEA partners) - a narrower information-exchange instrument, not a full DTA. No comprehensive DTA network beyond this was identified, and one source specifically notes the absence of a bilateral treaty between Niue and France as creating dual-taxation exposure risk for French expatriates, illustrating the network's general narrowness.