Nauru

Research notes

Nauru — family-office tax dossier

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

Summary

Nauru has no general personal income tax. Employment and Services Tax applies to wages and service fees, and Business Tax (20% for individuals) applies to persons conducting a business; since 1 January 2021 resident businesses are taxed on worldwide income. Whether a resident family managing its own portfolio is 'conducting a business' (defined as any activity for economic gain) is unclear, so gains and foreign dividends are left unknown. Dividends from Nauru companies are excluded. No inheritance, gift or wealth tax was found. Nauru sells citizenship from USD 90,000 (offer to 31 December 2026).

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.

Residence and eligibility

Employment and Services Tax Act 2014 s. 7 and Business Tax Act 2016 s. 8 define resident individuals; the explanatory memoranda list factors (OECD CRS residency sheet). Detailed tests not read.

• Naoero Economic and Climate Resilience Citizenship Program (EU, US, OTHER): Contribution USD 90,000 for a principal applicant under a limited-time offer to 31 December 2026 (USD 25,000 discount), USD 2,000 per additional dependant aged 16+, USD 15,000 per sibling; plus application fees (USD 5,000 + 2,000 per dependant), due diligence (USD 6,000 + 3,000 per dependant 16+), bank fees and USD 500 per passport. No residence requirement; dual citizenship allowed. Citizenship does not create tax residence. Minimum: 90,000 USD.
• Residence permit (EU, US, OTHER): Not researched.

Capital gains

Standard regime

No capital gains tax as such. Business profits tax applies to gross revenue from conducting a business, including 'a gain on disposal of a business asset' (BTA s. 17(1)(b)); since 1 January 2021 residents are taxed on worldwide amounts (s. 17(2A)). 'Business' means 'any activity, whether continuous or short term, conducted for the purposes of economic gain, other than an employment' (s. 3), which could arguably cover managing a large portfolio. Rates left unknown.

• Tax year / confidence / verification: 2026 / low / unverified (checked 2026-10-15)
• JSON numbers: headline 20% (0.2); listed domestic null (unknown); listed foreign null (unknown); private business sale null (unknown); local real estate null (unknown); foreign real estate null (unknown).
• How derived: If portfolio management is a business: gains on business assets at 20% (individual BPT rate; NRO). If not: 0. Not resolved, so null.
• Trader recharacterisation: The broad statutory definition of 'business' is the issue: any activity for economic gain.

Dividends

Standard regime

Distributions by a resident company, partnership or trust are excluded from gross revenue (BTA s. 17(2)(a)). Foreign dividends are taxed only if they are proceeds of a business (worldwide basis since 2021, with a foreign tax credit); whether a passive investor is in business is unresolved, so the foreign rate is left unknown.

• Exemptions and thresholds: Individuals' business profits tax 20%; Nauruan residents have a AUD 250,000 tax-free threshold (NRO).
• Tax year / confidence / verification: 2026 / low / partially_verified (checked 2026-10-15)
• JSON numbers: headline 20% (0.2); domestic 0% (0.0); foreign gross null (unknown); foreign tax relief: credit.
• How derived: Domestic: s. 17(2)(a) excludes resident-company distributions = 0. Foreign: 20% if part of a business, else 0; null pending clarification.
• Outbound withholding: Non-resident tax 20% on interest, royalties and insurance premiums (NRO); dividends not listed.
• Treaty network: No comprehensive treaties found (not verified).

Inheritance and gifts to children

Standard regime

No inheritance, estate or gift tax: none appears among the tax laws administered by the Nauru Revenue Office.

• 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.

Wealth tax

Standard regime

No net wealth tax: the NRO administers only the Revenue Administration Act, Employment and Services Tax Act, Business Tax Act, Telecommunications Service Tax Act and Gaming Act.

• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-15)
• JSON: type none.
• Property tax (not a wealth tax): Not researched.

Special regimes

The citizenship programme is described under Residence; it is not a tax regime.

Company taxation (kept separate from personal tax)

Headline rate in JSON: null (unknown). Business profits tax on companies at rates depending on category, residence and turnover (not verified); individuals 20%; small business tax 2.5% of gross revenue for non-resident individuals with turnover up to AUD 250,000; worldwide basis for residents since 2021.

Cost of living notes

Not sourced.

Open questions

• Whether passive portfolio income of a resident individual is business income (decisive for the scored rates).
• [standard/capital_gains] Ask the NRO whether a resident individual's passive portfolio (foreign listed shares) is a 'business' under BTA s. 3; the NRO 'Guide to Completing Schedule 1 - Foreign Income' was not read.
• [standard/inheritance] Land in Nauru is almost entirely customary/landowner-held; not researched.

Sources

• Business Tax Act 2016 (consolidated, as of 1 January 2021): https://naurufinance.info/wp-content/uploads/2023/05/Business-Tax-Act-2016.pdf
• Nauru Revenue Office (BTA worldwide taxation from 1 January 2021): https://naurufinance.info/nauru-revenue-office/
• NRO administered legislation (ESTA, BTA and rates): https://naurufinance.info/nro-administered-legislation/
• Nauru: Information on residency for tax purposes (CRS): https://www.oecd.org/content/dam/oecd/en/topics/policy-issue-focus/aeoi/nauru-tax-residency.pdf
• Naoero Economic and Climate Resilience Citizenship Program: contribution and fees: https://www.ecrcp.gov.nr/contribution
• Naoero ECRCP: frequently asked questions: https://www.ecrcp.gov.nr/frequently-asked-questions

Change log

• 2026-10-15: initial research.