domicile.wiki

New Caledonia

Taxes, residence and daily life for people moving to New Caledonia: for a wealthy family, an expat employee and a remote worker. Researched .

Open New Caledonia in the interactive guide

At a glance

For an EU-citizen family of five living off a €30M portfolio, the guide's default reader. The interactive guide recomputes everything for other passports and situations.

Tax on a €30M portfolio
€428,933 a year
Wealth tax
none
Children inherit
taxed
EU member
no
Currency
XPF
Capital
Nouméa

Tax on investments, inheritance and wealth

New Caledonia has its own tax code, separate from France. Private investors' gains on securities are generally untaxed; only real estate gains are taxed (24%). Dividends from local companies bear a 20% final withholding. Foreign dividends appear to fall into progressive income tax, up to 40%. There is no wealth tax. Inheritances and gifts to children are taxed at 5%-20% on worldwide assets when the deceased was resident.

Inheritance law and trusts

French civil law applies, so children have a protected share (the réserve) that a will cannot cut. People with Kanak customary status follow custom on customary land. A foreign resident cannot choose their national law, and the EU Succession Regulation does not apply. The Hague Trusts Convention is not in force for France.

Daily life, scored out of 100

From public indicators (World Bank, UNDP, Transparency International and others); higher is better.

MeasureScore
Legal system and property rights54
Healthcare quality and access70
Infrastructure and connectivity82

Research notes

New Caledonia — family-office tax dossier

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

Summary

New Caledonia has its own tax code, separate from France. Private investors' gains on securities are generally untaxed; only real estate gains are taxed (24%). Dividends from local companies bear a 20% final withholding. Foreign dividends appear to fall into progressive income tax, up to 40%. There is no wealth tax. Inheritances and gifts to children are taxed at 5%-20% on worldwide assets when the deceased was resident.

Residence and eligibility

Domicile if any of: home or principal place of stay in New Caledonia, main professional activity there, or centre of economic interests there. The France-New Caledonia treaty has tie-breakers (permanent home, vital interests, habitual abode).

Routes:

US citizens: No US-New Caledonia tax treaty; US citizens would pay New Caledonian tax plus US federal tax, with foreign tax credits on the US side.

Capital gains

Capital gains of individuals are generally not taxable. Exception: private real estate gains (PVI) are taxed at 20% plus 4% CCS (24% in total), with exemptions and special rules.

Rate basis: PwC (reviewed 9 Sep 2026): 'Capital gains derived by individuals are generally not taxable', except real estate (PVI 20% + CCS 4%). Securities and private business shares 0. Real estate 0.24 is the headline before any holding-period relief (relief not researched). Foreign real estate assumed outside PVI.

Professional trader: Habitual trading could be business income under the progressive scale; not researched.

Foreign assets: No tax on gains from foreign securities found.

Confidence: medium; verification: partially_verified.

JSON: headline 0.24; listed domestic 0.0, listed foreign 0.0, private business 0.0, local real estate 0.24, foreign real estate 0.0.

Dividends

Dividends from New Caledonian companies bear 20% at source (IRVM 11.5% + CCS 4% + additional centimes 4.5%) and are not subject to personal income tax. Foreign dividends are not covered by IRVM and appear to be taxed in personal income tax at progressive rates up to 40%, with a foreign tax credit.

Rate basis: Domestic: 0.20 final (PwC income determination; DSF IRVM page 'total de 20%'). Foreign: residents are taxed on worldwide income at 0-40% (PwC), and IRVM applies only to distributions by companies with their seat in New Caledonia (DSF), so foreign dividends are assumed to fall into the progressive scale at the 40% top rate. PwC mentions foreign tax credits. Low confidence for foreign dividends.

Withholding outbound: Dividends paid to non-residents: about 20% for individuals, 21% for companies (IRVM + CCS + centimes, plus possibly CAIS 3%); France-New Caledonia treaty: 15% individuals, 5% companies.

Treaty network: Only one comprehensive treaty, with France (1983). No treaty with the US or other EU states.

Holding company notes: IRVM reinvestment reduction (art. Lp 543.2-I) for local reinvestment; not relevant to a foreign portfolio.

Confidence: low; verification: partially_verified.

JSON: domestic 0.2, foreign gross 0.4, foreign tax relief 'credit'.

Inheritance and gifts to children

Inheritance and gift duties are charged on each beneficiary. If the deceased or donor was resident in New Caledonia, worldwide assets are taxed; otherwise only New Caledonian assets. Children: progressive rates of 5% to 20% after an allowance of XPF 100,000. Spouses and PACS partners are exempt. Modelled as 20% on everything above XPF 100,000 per child.

Foreign assets: Worldwide assets when the deceased/donor is a tax resident of New Caledonia; local assets only otherwise.

Gift tax: Gifts follow the same rules as inheritances 'but some differences could exist' (PwC).

Domicile rules: Based on the tax domicile of the deceased or donor in New Caledonia.

Law: code des impôts de Nouvelle-Calédonie, art. 248-417 (droits d'enregistrement, DSF). The consolidated code was not reachable (juridoc PDF returned 404; the new Leginova portal, live since 1 Oct 2026, is a JavaScript application). JSON: exemption XPF 100,000, single 20% bracket, as an upper bound.

Confidence: low; verification: partially_verified.

JSON: basis 'beneficiary', children 'taxed', exemption 100,000 XPF, brackets [{"from_amount": 0, "rate": 0.2}].

Surviving spouse: PwC states that no inheritance tax is due between spouses or PACS partners; its separate line giving a XPF 100,000 allowance and 5%-20% rates for 'direct dependants (spouse or partner)' is ambiguous, and the local Code des impots (arts. 248-417) could not be opened, so confidence is medium.

Wealth tax

No net wealth tax (PwC).

Property tax note: Contribution foncière on land and buildings, computed from surface area times a rate per m2 and then 8.4% (buildings) or 0.7875% (land), varying by commune (PwC).

Confidence: high; verification: partially_verified.

JSON: type 'none'.

Special regimes

None found. New Caledonia has no regime for wealthy new residents.

Company taxation (kept separate from personal tax)

CIT rate in JSON: 0.3. CIT 30% (15% for smaller companies below turnover thresholds; 35% mining and metallurgy), plus CAIS 3% on distributions above XPF 30M and an additional social contribution of 5%-15% for large profits. Taxed on New Caledonian-source income.

Cost of living notes

Not sourced in this pass (no cost_of_living block). Markers: Nouméa (-22.2763, 166.4572; Wikipedia (Nouméa), approx.).

Open questions

Sources

Change log

Residence and succession sources

Tax sources are cited in the research notes above.