Cook Islands

Research notes

Cook Islands — family-office tax dossier

Last reviewed: 2026-10-15 Tax year: 2026 Reviewer: research agent (Claude), unreviewed by a tax adviser

Summary

Residents pay income tax on worldwide income at up to 30% (above NZD 80,000 on Rarotonga). There is no capital gains tax: only gains from dealing or from property bought for resale are income. Dividends, foreign ones included, are ordinary income at up to 30%, with credit for foreign tax. No wealth, estate or gift tax was found.

Residence and eligibility

An individual is resident if their home is in the Cook Islands (Income Tax Act 1997 s.82(1)). The standard deduction may be apportioned by residence or days present.

Routes:

• Residence permit (Cook Islands immigration) (EU, US, OTHER): The Cook Islands controls immigration itself, including for New Zealand citizens who are not Cook Islanders. Long-term residence needs a permit (details not researched).

US citizens: No US treaty. US citizens pay US federal tax on worldwide income with credit for Cook Islands tax; US estate tax applies.

Capital gains

No capital gains tax. Gains on property are income only if the taxpayer deals in such property, acquired it for resale, or made them in a profit-making scheme (Income Tax Act 1997 s.46(1)(c)).

Rate basis: Income Tax Act 1997 s.46(1)(c) taxes only gains from dealing, from property bought for resale, or from profit-making schemes. A long-term investor's gains on listed securities, business shares and real estate are therefore scored at 0.

Professional trader: Frequent trading or buying for resale makes gains ordinary income at up to 30% (s.46(1)(c)).

Foreign assets: Same rule for foreign assets.

Confidence: medium; verification: partially_verified.

JSON: headline 0.0; listed domestic 0.0, listed foreign 0.0, private business 0.0, local real estate 0.0, foreign real estate 0.0.

Dividends

All dividends are assessable income (s.46(1)(g)) at the individual's marginal rate, up to 30%. Foreign income tax on foreign income is credited (s.85).

Rate basis: Top rate 30% (MFEM tax rates; above NZD 80,000). Dividends are gross income under s.46(1)(g). No imputation system was found in the 1997 Act; companies may elect to deduct dividends (s.59(k)).

Withholding outbound: 15% withholding tax on dividends, interest and royalties paid to non-residents (s.100).

Treaty network: No comprehensive treaties; agreements with New Zealand and Australia cover only allocation of taxing rights for certain individuals' income and transfer-pricing MAP. TIEAs and CRS in place.

Confidence: medium; verification: partially_verified.

JSON: domestic 0.3, foreign gross 0.3, foreign tax relief 'credit'.

Inheritance and gifts to children

No estate, inheritance or gift duty was found: the tax legislation MFEM administers covers income tax, VAT, departure tax and customs only.

Gift tax: No gift duty found.

Domicile rules: Not applicable.

Confidence: low; verification: partially_verified.

JSON: basis 'none', children 'fully_exempt', exemption 0 NZD, brackets [].

Wealth tax

No net wealth tax. The tax legislation MFEM administers covers income tax, VAT, departure tax and customs only.

Property tax note: No general property tax was found; most land is customary land held under leases.

Confidence: medium; verification: partially_verified.

JSON: type 'none'.

Special regimes

None found for individuals. The international company and trust regimes concern non-resident structures and are outside the personal-holding scope.

Company taxation (kept separate from personal tax)

CIT rate in JSON: 0.2. Resident companies 20% (Income Tax Act 1997 First Schedule). Company residence was narrowed in 2021 (Income Tax (Company Residence) Amendment Act 2021) so that most international companies are not resident.

Cost of living notes

Not sourced in this pass (no cost_of_living block). Markers: Avarua (-21.2078, -159.775; Wikipedia (Avarua), approx.).

Open questions

• Consolidated current text of the Income Tax Act 1997 (amendments to 2023) not read; scanned amendment PDFs not OCR'd.
• Immigration and residence permit requirements not researched.
• [standard/capital_gains] Later amendments to s.46 (Income Tax Amendment Acts 1997-2023, several only as scanned PDFs) were not all read.
• [standard/capital_gains] Treatment of land sales (MFEM 'Taxation of Land Transactions' guidance) not read; that PDF is a scan.
• [standard/dividends] Whether any amendment introduced imputation credits or a final withholding for resident shareholders was not checked.
• [standard/inheritance] No statement explicitly confirming the absence of estate/gift duty was found; inferred from the list of tax legislation.

Sources

• Cook Islands Income Tax Act 1997 (No. 12 of 1997): https://www.mfem.gov.ck/_files/ugd/dbdf40_ef039a088ac247b2aeaf8dcc59fb90a6.pdf
• MFEM Revenue Management Division: Tax rates - Rarotonga (from 1 Jan 2021) and Pa Enua (from 1 Jul 2023): https://www.mfem.gov.ck/inland-revenue
• MFEM: Tax Acts, Regulations, Policy, Rulings and Court Cases (list of tax legislation administered): https://www.mfem.gov.ck/policy-court-cases-rulings
• MFEM Public Consultation - Tax residency rules for companies (22 Nov 2021): https://www.mfem.gov.ck/_files/ugd/dbdf40_15e3585ddaa64bf7953dd761c94ed1dd.pdf

Change log

• 2026-10-15: initial research.