Asia-Pacific

Samoa

Corporate rate
27%
Top personal rate
27%
VAT / GST rate
15%
One-sentence summary Corporate tax: 27% standard rate. Personal income tax: Progressive up to a 27% top rate. VAT/consumption tax: 15% standard sales tax (VAGST).

Tax System

Samoa taxes resident individuals and companies on worldwide income, while non-residents are taxed on Samoa-source income only, administered by the Ministry for Revenue. Entities registered under the International Companies Act 1987 as International Companies are exempt from Samoa income tax, capital gains tax, stamp duty, and other local taxes entirely, provided they do not conduct business in Samoa or derive Samoa-source income.

Tax Year & Key Deadlines

The tax year generally follows the calendar year for individuals; companies may adopt an approved accounting period, and tax returns are administered by the Ministry for Revenue's Inland Revenue Services division.

Corporate Tax Rate

27% standard rate.

Personal Tax Rate

Progressive up to a 27% top rate.

VAT / GST Rate

15% standard sales tax (VAGST).

Residency

An individual is a Samoa tax resident if domiciled in Samoa or present in Samoa for 183 days or more in any 12-month period; under Samoa's Income Tax Act, an individual who becomes or ceases to be resident partway through a tax year is treated as resident only for the portion of the year they were actually present. Resident individuals and companies are taxed on worldwide income; non-residents are taxed on Samoa-source income only. Separately, entities registered under the International Companies Act 1987 as International Companies (ICs) - Samoa's offshore regime - are exempt from Samoa income tax, capital gains tax, stamp duty, and other local taxes entirely, provided they do not conduct business in Samoa or derive Samoa-source income; this is a statutory exemption built into the Act itself, not case-by-case relief.

Permanent Establishment

A foreign company that establishes a taxable presence (permanent establishment) in Samoa, depending on the nature and duration of its activities, becomes liable for corporate income tax on the profits attributable to that establishment. Regardless of permanent establishment status, a foreign company employing staff in Samoa must register as an employer and comply with PAYE and Samoa National Provident Fund (SNPF) obligations for those employees.

CFC (Controlled Foreign Company) Rules

No Controlled Foreign Company regime was identified in available sources for Samoa.

Thin Capitalization

For Samoa's offshore International Companies (IOFC entities), a specialist source confirms there are no thin capitalization rules or prudential debt-equity requirements. For ordinary domestic resident companies, no general statutory thin capitalization ratio was separately identified - do not assume the offshore-entity exemption extends to domestic companies without confirming directly with the Samoa Ministry for Revenue.

Hybrid Entity Rules

Samoa classifies entities under its own domestic Income Tax Act 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 Samoa having no CFC regime of its own. Samoa International Companies are commonly used in cross-border structuring as disregarded or pass-through entities under a foreign owner's home-country check-the-box election, a classification choice made under the foreign owner's own law rather than Samoa's.

Foreign Bank Account / Foreign Financial Asset Reporting

No domestic FBAR-equivalent regime requires Samoa residents to separately disclose foreign financial accounts. Samoa is a CRS participating jurisdiction, with its own domestic CRS guidance issued by the Commissioner of Inland Revenue, 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 Samoa's own rules.

Participation Exemption

No participation exemption regime for dividends or capital gains from a qualifying subsidiary was identified for ordinary resident companies; capital gains are generally treated as ordinary income taxed at the applicable income tax rate (up to 27%), with no separate capital gains tax regime or distinct participation-based exemption mechanism.

Foreign Tax Credit

A dedicated unilateral foreign tax credit provision is not confirmed in available primary sources. Samoa's primary and effectively only comprehensive double taxation agreement is with New Zealand, which provides the main relief mechanism for double taxation on income connecting Samoa and New Zealand; relief for foreign tax paid outside that specific relationship should not be assumed available.

Treaty Network

Very limited: Samoa's primary and, per available sources, effectively only comprehensive double taxation agreement is with New Zealand, reflecting close economic, cultural, and migration ties (a large Samoan diaspora resides in New Zealand and Australia). No broader named treaty network is confirmed in available sources.

Official tax authority: Inland Revenue Services, Ministry of Customs and Revenue - revenue.gov.ws
Sources: TaxAtlas - Samoa tax system, residency and treaty network, OECD - Samoa Tax Residency Rules, Samoa International Companies Act 1987 exemption summary, BRITACOM - Samoa tax laws and policies (AEOI/EOIR/BEPS participation). Page last verified: August 08, 2026. General information only - confirm current rates with a licensed advisor in this jurisdiction before relying on this page.