Fiji

Research notes

Fiji — family-office tax dossier

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

Summary

Fiji taxes residents' capital gains on worldwide assets at a flat 10% capital gains tax (CGT), with foreign tax credit; gains on shares listed on the South Pacific Stock Exchange are exempt. Dividends have been exempt from income tax since 1 August 2017 (FRCS); whether this also covers foreign dividends is not confirmed. No inheritance, gift or wealth tax was found; transfers on death are CGT-deferred. Resident income tax rates run to 39% above FJD 1 million (from 2024).

US citizens: US citizens remain subject to US federal income, estate and gift tax on worldwide income and assets wherever they live; the app adds the federal layer. Where local tax on portfolio income is nil there is nothing to credit against US tax. Fiji's 10% CGT on foreign gains is creditable against US tax on the same gain in principle; no US-Fiji treaty.

Residence and eligibility

Income Tax Act 2015 residence test (183 days in a 12-month period, or domicile/permanent place of abode, as commonly reported; not verified against the Act). Residents are taxed on worldwide income and gains.

• Residence/investor permit (EU, US, OTHER): Not researched. Fiji has no residence-by-investment tax regime for wealthy arrivals as far as checked.

Capital gains

Standard regime

Capital gains tax of 10% applies to gains on disposal of capital assets by Fiji residents regardless of where the asset is located, including shares, securities and real property; a foreign tax credit is available for tax paid abroad on foreign capital assets. Gains on shares listed on the South Pacific Stock Exchange (SPSE) are exempt.

• Exemptions and thresholds: Resident individuals and Fiji citizens: gains up to FJD 30,000 exempt; first residential property or principal place of residence exempt; SPSE-listed shares exempt; shares held since before 1 May 2011 exempt; assets of a deceased estate disposed of within 2 years of death exempt.
• Important exceptions, statute references and announced changes: From 1 August 2025 (Income Tax (Budget Amendment) Act No. 9 of 2025) share buy-backs, redemptions, liquidations and reorganisations no longer give a tax-free deemed dividend; the gain is CGT (or income if on revenue account). CGT return due within 30 days of each disposal (except SPSE shares).
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-15)
• JSON numbers: headline 10% (0.1); listed domestic 0% (0.0); listed foreign 10% (0.1); private business sale 10% (0.1); local real estate 10% (0.1); foreign real estate 10% (0.1).
• How derived: FRCS CGT page: 'a tax levied at 10% on profits or gains realized from the disposal of capital assets'; residents taxed on gains 'regardless of the asset's location'. Domestic listed = SPSE shares (exempt) = 0. Foreign listed shares, private company shares and real estate = 10% (before foreign tax credit).
• Trader recharacterisation: Assets held as trading stock or on revenue account are outside CGT and taxed as income at up to 39%.
• Foreign assets: Worldwide for residents; credit for foreign tax paid on foreign capital assets. Non-residents are taxed only on Fiji assets.

Fiji is one of the few Pacific states with a genuine worldwide CGT for residents. For the family: foreign listed shares 10% (credit for any foreign CGT, usually none), private business sale 10%. Holding the portfolio through a company does not change the scored rate.

Dividends

Standard regime

FRCS Practice Statement 39/2017 states that from 1 August 2017 dividends paid to residents and non-residents are exempt from income tax (Part 5 of the Income Tax (Exempt Income) Regulations: 'all dividends are exempt from taxation'). Fiji-company dividends are therefore 0%. The exemption is worded generally ('all dividends'), so foreign dividends appear exempt too, but no FRCS text addressing foreign-source dividends was found: low confidence on the foreign rate.

• Exemptions and thresholds: Resident individual income tax from 1 January 2024: 0% to FJD 30,000; 18% to 50,000; 20% to 270,000; then 33%-38% bands; 39% above FJD 1,000,000 (Social Responsibility Tax folded into the brackets). Unchanged in the 2025-26 and 2026-27 budgets.
• Important exceptions, statute references and announced changes: 2025-26 budget removed deemed-dividend treatment of capital returns on buy-backs, redemptions and liquidations (now CGT).
• Tax year / confidence / verification: 2026 / low / partially_verified (checked 2026-10-15)
• JSON numbers: headline 0% (0.0); domestic 0% (0.0); foreign gross 0% (0.0); foreign tax relief: not_applicable.
• How derived: PS 39/2017 para 6 and note (1): with effect from 1 August 2017 all dividends are exempt. 'Dividend' is defined by reference to a distribution of profits by a 'company', which includes foreign bodies, so foreign dividends = 0 (low confidence). If foreign dividends were instead ordinary income, the rate would be up to 39%.
• Outbound withholding: No dividend withholding since 1 August 2017 (dividends exempt for non-residents as well).
• Treaty network: Small network (Australia, NZ, UK, Singapore, Malaysia, Korea, PNG and others reported; not verified). No US treaty: US dividends bear 30% US WHT, a final cost.

Rate table (FRCS SIG, 2024): resident chargeable income 1,000,001+ pays FJD 318,500 + 39% of the excess. Dividends are outside this table because they are exempt.

Inheritance and gifts to children

Standard regime

No inheritance, estate or gift tax was found. Estate and gift duties were discontinued by a 1985 amendment act (reported; PacLII text could not be opened). Transfers on death to an executor or beneficiary are deferred for CGT (no gain recognised; the heir takes over the cost base), and assets sold by the estate within 2 years of death are exempt.

• Tax year / confidence / verification: 2026 / low / partially_verified (checked 2026-10-15)
• JSON numbers: basis none; children fully_exempt; exemption 0; brackets []; other transfer costs 0.0.
• Gift tax: No gift tax found. Gifts of principal residences, first residential properties or 'interests in capital assets between family members' are CGT-deferred; other gifts may be CGT disposals.
• Foreign assets: No Fiji inheritance tax on any assets (as found).
• Residence/domicile rules: Not applicable.

CGT deferral on death (FRCS CGT page, 'Transfers due to the death of a person to an executor or beneficiary') means no deemed-disposal charge at death; JSON deemed_disposal_rate 0.

Wealth tax

Standard regime

No net wealth tax and no recurring levy on financial assets.

• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-15)
• JSON: type none.
• Property tax (not a wealth tax): Municipal councils levy property rates on land in their areas (not researched).

Special regimes

None found for wealthy new residents.

Company taxation (kept separate from personal tax)

Headline rate in JSON: null (unknown). FRCS states the corporate income tax rate was increased with effect from 1 August 2023 (widely reported as 25%, from 20%), but the rate was not seen in an official source in this session. Company dividends exempt from 1 August 2017. Tax-free region incentives exist.

Cost of living notes

Not sourced.

Open questions

• Westpac (July 2026) reports the 2026-27 budget left personal and corporate income tax rates unchanged; the 2026-27 FRCS budget guideline was not read.
• Residence routes for foreign investors not researched.
• [standard/capital_gains] The Income Tax Act 2015 itself (PacLII) could not be opened (HTTP 403); rules taken from FRCS guidance.
• [standard/capital_gains] Whether a gift of shares to a child outside the family-member deferral (principal residence, first home, 'interests in capital assets between family members') is a taxable disposal at market value was not verified.
• [standard/dividends] Confirm in the Income Tax (Exempt Income) Regulations 2016 Part 5 (as amended 2017) that foreign-source dividends of resident individuals are exempt.
• [standard/dividends] An FRCS FAQ page (2017) still says dividends are exempt only if paid from profits taxed at corporate level; it appears to predate the August 2017 change.
• [standard/inheritance] Primary source for abolition of estate and gift duty not opened (PacLII blocked).
• [standard/inheritance] Stamp Duties Act repealed from 1 August 2020 (reported); whether any transfer charge applies to inherited land not verified.

Sources

• Capital Gains Tax (FRCS guidance page, updated 1 July 2025): https://frcs.org.fj/?p=27702
• Standard Interpretation Guideline 2026-07: Income Tax Act 2015 - National Budget Amendments 2025-2026: https://frcs.org.fj/files/2026/06/SIG-on-Income-Tax-Act-2015-National-Budget-Amendments-2025-2026.pdf
• Practice Statement 39/2017: Taxation of Dividends: https://frcs.org.fj/files/2025/06/PS-39-Dividend-2017-REF-39-2017.pdf
• Exemptions for salary and wage earners (FRCS FAQ page, 2017): https://frcs.org.fj/?p=27738
• Standard Interpretation Guideline: Change in Individual Income Tax Rates (from 1 January 2024): https://frcs.org.fj/files/2024/05/SIG-on-Change-in-Individual-Income-Tax-Rates.pdf
• Financial planning in Fiji (guide, updated 2026-06-13): https://www.globalinvestments.net/financial-planning/guides/financial-planning-fiji
• Fiji: July 2026 economic update (2026-27 budget): https://www.westpaciq.com.au/economics/2026/07/fiji-jul-26-economic-update/

Change log

• 2026-10-15: initial research.