Fiji Corporate Income Tax

Company tax rates

• Standard corporate income tax rate — 25% (Income Tax Act 2015 (https://taxatlas.io/country/fiji/corporate-tax))
• Reduced rate — South Pacific Stock Exchange listed companies — 10% reduced rate on profits attributable to qualifying new equity raised through SPX listing ((approx — confirm scope and conditions)) (Income Tax Act 2015 (https://taxatlas.io/country/fiji/corporate-tax))
• Non-resident company rate — 25% on Fiji-source income (branches of foreign companies taxed at the standard rate) ((approx — confirm any branch profits surcharge)) (Income Tax Act 2015)
• Investment incentives — Tax holidays (e.g. for hotel/tourism and approved activities) and a film production tax rebate are available for qualifying investments ((approx — confirm exact incentive terms and eligibility)) (Income Tax (Allowances, Deductions and Exemptions) Regulations 2016 (https://taxatlas.io/country/fiji/corporate-tax))

Fiji taxes resident and non-resident companies on Fiji-source income, with a number of reduced rates and incentive regimes. Confirm incentive eligibility with FRCS.

Tax base and withholding taxes

• Corporate tax base — Net assessable income (gross income less allowable deductions) on a Fiji-source basis for non-residents and worldwide for residents (Income Tax Act 2015)
• Withholding tax on dividends to non-residents — Dividends — position uncertain: some sources cite 0% (dividend WHT removed effective 1 August 2017), others cite 15% ((approx — CONFIRM current dividend WHT treatment with FRCS; sources conflict)) (Income Tax Act 2015 (https://taxsummaries.pwc.com/quick-charts/withholding-tax-wht-rates))
• Withholding tax on interest to non-residents — 10% ((approx — reduced under applicable double tax treaties)) (Income Tax Act 2015 (https://taxsummaries.pwc.com/quick-charts/withholding-tax-wht-rates))
• Withholding tax on royalties to non-residents — 15% ((approx — reduced under applicable double tax treaties)) (Income Tax Act 2015 (https://taxsummaries.pwc.com/quick-charts/withholding-tax-wht-rates))
• Withholding tax on management/professional/know-how fees to non-residents — Generally 5%–15% depending on the nature of the payment and the treaty position ((approx — confirm specific rate per payment type)) (Income Tax Act 2015 (https://frcs.org.fj/our-services/taxation/business/withholding-tax/))
• Company return filing deadline — Within 3 months of the end of the tax year (i.e. 31 March for calendar-year taxpayers) ((approx — confirm; tax-agent lodgement extensions and substituted accounting periods may apply)) (Tax Administration Act 2009)
• Provisional / advance corporate tax — Companies generally pay tax in advance instalments during the year, reconciled on lodgement ((approx — confirm instalment schedule)) (Tax Administration Act 2009)

The corporate tax base is net business profit computed under the Income Tax Act. Fiji applies withholding taxes to certain payments to non-residents, often reduced by tax treaty.