Samoa

Research notes

Samoa — family-office tax dossier

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

Summary

Samoa taxes residents on worldwide income at up to 27%. Its capital gains tax (27%) applies only to capital assets held for three years or less; gains on assets held longer, and on foreign assets bought before becoming resident, are exempt. Dividends from Samoan companies are exempt, but foreign dividends are taxable at up to 27% with a foreign tax credit. No inheritance, gift or wealth tax was found.

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

Income Tax Act 2012 s. 6: resident individual if the individual has a home in Samoa during the year, or is present for 183 days in any 12-month period commencing or ending in the tax year (part-year rules on arrival and departure).

• Residence permit (EU, US, OTHER): Not researched.

Capital gains

Standard regime

Capital gains tax at 27% applies to a resident's net capital gain on disposal of capital assets anywhere, but gains on assets held for more than three years are exempt, as are gains on foreign (non-Samoan) assets acquired before becoming resident and on the principal residence. Cost is uplifted by 5% a year. For a long-term investor the rate is 0%.

• Exemptions and thresholds: Income Tax Act 2012 s. 66(1): (a) assets acquired on or before 31 December 1989; (b) principal place of residence; (c) assets held for more than 3 years; (d) non-Samoan assets acquired before becoming resident; (f) estate disposals that would have been exempt for the deceased. s. 65(2): cost increased by 5% per annum.
• Important exceptions, statute references and announced changes: s. 63 and Schedule 1 para (8): CGT rate 27%. The 2025 IR2 return still asks 'Did you make a capital gain on an asset you bought and sold within three years?' at 27%. Gains on assets acquired for resale (s. 16(1)(b)) or held in a business are ordinary income at up to 27%.
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-15)
• JSON numbers: headline 27% (0.27); listed domestic 0% (0.0); listed foreign 0% (0.0); private business sale 0% (0.0); local real estate 0% (0.0); foreign real estate 0% (0.0).
• How derived: Assumes holding periods over 3 years (guide: held longer than any holding period), so s. 66(1)(c) exempts the gain: 0 for all classes. Short-term (<= 3 years) gains: 27% with credit for foreign tax (s. 67).
• Holding period: More than 3 years = exempt; 3 years or less = 27% CGT.
• Trader recharacterisation: Net gains from assets acquired with the purpose of disposal at a profit are property income (s. 16(1)(b)) and business gains are business income, both at up to 27%.
• Foreign assets: Residents' net capital gain includes worldwide disposals (s. 64(1)); foreign assets acquired before becoming resident are exempt (s. 66(1)(d)).

Scoring note: the family's portfolio is long-term, so the scored CGT is 0%; active rebalancing within 3 years would be taxed at 27% on the gain (after the 5% annual cost uplift).

Dividends

Standard regime

Dividends paid by a resident (Samoan) company are exempt income (Schedule 2 Part A (1)(b)). Foreign dividends are property income of a resident (s. 16(1)(a)), taxed at the individual rates (27% above WST 25,000 per the 2025 return), with a foreign tax credit for foreign tax paid (s. 57).

• Exemptions and thresholds: 2025 individual rates (IR2 2025): 0% to WST 15,000; 20% on 15,000-25,000; 27% above 25,000. (The 2012 Act text had 0% to 12,000, 10%, 20%, 27% bands.)
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-15)
• JSON numbers: headline 27% (0.27); domestic 0% (0.0); foreign gross 27% (0.27); foreign tax relief: credit.
• How derived: Domestic: Schedule 2 Part A (1)(b) exempts 'a dividend paid by a resident company' = 0. Foreign: top individual rate 27% on property income before the s. 57 foreign tax credit (credit limited to Samoan tax on that income).
• Outbound withholding: Schedule 1 (4) lists non-resident WHT of 15% on interest, royalties and fees; dividends of resident companies are not in the list (no dividend WHT found).
• Treaty network: No comprehensive tax treaty found; Samoa has 17 tax information exchange agreements and applies the Multilateral Convention on Mutual Administrative Assistance (Ministry for Revenue). US dividends bear 30% US WHT, creditable up to the Samoan tax.

Inheritance and gifts to children

Standard regime

No inheritance, estate or gift tax was found among the taxes administered by the Ministry for Revenue. For CGT, transmission of an asset on death to the personal representative or a beneficiary is not a disposal giving rise to a gain (s. 73(1)(b)). A lifetime gift is a non-arm's-length disposal at market value (s. 74), which only matters for assets held 3 years or less.

• 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. A gift of an asset held 3 years or less can trigger 27% CGT on the market-value gain.
• Foreign assets: No Samoan transfer tax found on any assets.

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): Not researched.

Special regimes

None found for wealthy new residents.

Company taxation (kept separate from personal tax)

Headline rate in JSON: 27% (0.27). Company income tax 27% (Income Tax Act 2012 Schedule 1 (2)). Dividends from resident companies exempt. Samoa also has an international (offshore) companies regime, not researched.

Cost of living notes

Not sourced.

Open questions

• Residence permit routes not researched.
• [standard/capital_gains] The Act copy on the Ministry site is the 2012 text; later amendments (e.g. 2017) were not read, but the 2025 return confirms the 27% / 3-year rule.
• [standard/dividends] Whether a resident individual's foreign dividends are ever taxed as 'business income' at a different rate was not examined.
• [standard/inheritance] No official statement that Samoa has no estate or gift duty was found; absence inferred from the Ministry for Revenue's tax list and the Income Tax Act.
• [standard/inheritance] Stamp duty on transfers of land (if any) not researched.

Sources

• Income Tax Act 2012 (No. 21), including Part 4 Capital Gains Tax and Schedules 1-2: https://www.revenue.gov.ws/wp-content/uploads/2020/10/Income_Tax_Act_2012_eng.pdf
• IR2 Individual Income Tax Return 2025 (rate table and capital gains box): https://revenue.gov.ws/wp-content/uploads/2025/01/IR2-2025.pdf
• Inland Revenue Services (tax types, TIEAs): https://revenue.gov.ws/inland-revenue-services/
• Samoa: Information on residency for tax purposes (CRS): https://www.oecd.org/content/dam/oecd/en/topics/policy-issue-focus/aeoi/samoa-tax-residency.pdf

Change log

• 2026-10-15: initial research.