French overseas collectivity with its own tax autonomy since 2007, popularly known as a low-tax jurisdiction for qualifying long-term residents.
Saint Barthelemy has administered its own separate tax code, independent of mainland France's General Tax Code, since becoming a French overseas collectivity (Collectivite d'Outre-Mer) in 2007. The territory levies no corporate income tax, no personal income tax, and no VAT, relying instead on a 5% quay duty (droit de quai) on imported goods under Article 13 of the Code des contributions de Saint-Barthelemy.
A specific statutory tax year framework has limited practical relevance given the absence of corporate or personal income tax; the five-year local residence requirement described elsewhere on this page is the operative timing rule that matters for tax purposes, rather than an annual filing calendar.
0% - no general corporate income tax (listed among the roughly dozen jurisdictions worldwide with no general corporate income tax per Tax Foundation's 2025 global survey).
0% - a French Senate legislative report on Saint Barthelemy's fiscal autonomy (in effect since 2007) confirms there is neither corporate income tax nor personal income tax in the territory. The 5-year residency requirement referenced by some secondary sources relates to establishing fiscal domicile in Saint Barthelemy for anti-avoidance purposes (per the tax code's domicile rules), not to the underlying tax rate itself, which is zero regardless.
0% - no VAT and no general turnover tax (unlike neighboring Saint-Martin, which levies a 4% TGCA). Saint Barthelemy instead applies a 5% quay duty (droit de quai) on goods imported into the island, under Article 13 of the Code des contributions de Saint-Barthelemy.
Saint Barthelemy became a French overseas collectivity (Collectivite d'Outre-Mer) in 2007, detaching from Guadeloupe under Article 74 of the French Constitution, and since then has administered its own tax code separately from mainland France's General Tax Code, under the supervision of - but fiscally independent from - the French State. An individual who transferred tax residence to Saint Barthelemy after 15 July 2007 remains subject to French tax rules unless they satisfy a five-year local residence requirement; individuals meeting that five-year threshold are recognized as Saint Barthelemy tax residents and pay no French or local personal income tax on worldwide income (Saint Barthelemy's own system does not levy the French income tax code, VAT, or corporate tax locally). If a household's family or economic center of interests remains in France, French tax authorities may still treat the individual as French tax resident regardless of physical presence in Saint Barthelemy. A company is resident in Saint Barthelemy only if its place of effective management has been there for at least five years, or if it has been controlled by Saint Barthelemy residents for the same five-year period; companies not meeting this threshold are treated as French tax residents and can join a French tax consolidation group.
Because Saint Barthelemy levies no corporate income tax at all, the concept of a permanent establishment has no practical tax consequence for a foreign company operating on the island in the way it would in a jurisdiction with a conventional corporate tax base; a company is instead assessed under the five-year effective-management or five-year Saint Barthelemy-resident-control tests described in the Residency section of this page to determine whether it is treated as a Saint Barthelemy or a French tax resident for the limited purposes where that distinction still matters (such as French tax consolidation eligibility).
No CFC-specific provision under Saint Barthelemy's own separate tax code was found. This matters because France's own CFC regime (enacted 1980, 50% control threshold, reduced to 5% in certain low-tax-jurisdiction anti-abuse scenarios) is French national law and does not automatically extend to Saint Barthelemy's fiscally autonomous local tax code - the two systems should not be conflated. Given Saint Barthelemy's design as a low-friction personal tax regime for long-term residents rather than a jurisdiction with an active outbound corporate-investment base, the absence of a CFC-style mechanism is consistent with the system's overall structure, but confirm the current position directly with the Direction des Services Fiscaux or Saint Barthelemy-qualified counsel before relying on it for a specific corporate structure.
No thin capitalization ratio or related-party interest-deduction cap specific to Saint Barthelemy's own tax code was found.
Saint Barthelemy classifies entities under its own separate 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 the absence of a CFC regime described elsewhere on this page; France's own national anti-hybrid rules under its implementation of the EU Anti-Tax Avoidance Directive are French national law and do not automatically extend to Saint Barthelemy's fiscally autonomous local tax code, and the two systems should not be conflated.
No domestic FBAR-equivalent regime requires Saint Barthelemy residents to separately disclose foreign financial accounts. Saint Barthelemy is a CRS participating jurisdiction: it has been treated as a Reportable Jurisdiction for CRS purposes since 2016, alongside French Saint-Martin and the French overseas departments, reflecting the same EU savings-taxation and administrative-cooperation agreement extended to the territory (described elsewhere on this page). US persons remain independently subject to FinCEN Form 114 (FBAR) and potentially Form 8938 regardless of Saint Barthelemy's own rules.
Not a meaningful question in Saint Barthelemy's case: with no corporate income tax at all, dividends and capital gains from a subsidiary are already outside the local tax base entirely, achieving a more complete practical effect than a conventional participation exemption regime would provide.
Not a meaningful question given the absence of corporate or personal income tax in Saint Barthelemy: with no domestic tax base against which foreign tax paid could be credited, a foreign tax credit mechanism has no practical function locally; the EU savings-taxation and administrative-cooperation agreement extended to Saint Barthelemy (described elsewhere on this page) instead addresses information exchange rather than double-tax relief.
Saint Barthelemy is not part of the European Union's fiscal or customs territory despite France's EU membership - it gained "overseas country or territory" status (rather than EU outermost region status) effective 1 January 2012. The EU and France concluded a specific agreement extending EU savings-taxation and administrative-cooperation legislation to Saint Barthelemy, addressing the transparency gap this special status would otherwise create. As a matter of French sovereignty, Saint Barthelemy residents are French citizens and the territory does not independently negotiate its own bilateral double tax treaties; treaty questions for Saint Barthelemy-connected income should be analyzed through the lens of Saint Barthelemy's own five-year-residence tax rules combined with France's treaty network and EU agreements, rather than assuming Saint Barthelemy has a freestanding treaty network of its own.