• Gibraltar Tax System

  • TAX RESIDENCY

    Tax Residency

    A company is considered to be tax resident in Gibraltar if its management and control is exercised in Gibraltar.

    Taxable Basis

    Gibraltar tax resident companies are taxed on income accrued in and derived from Gibraltar.

    Non-Gibraltar tax resident companies are taxed only on income generated in Gibraltar.

  • TAX ADMIN

    Taxable Period

    The taxable period for a company in Gibraltar is its accounting year.

    Tax Returns

    Every company needs to submit an annual tax return within 6 months from the end of its accounting period.

    Companies with turnover of more than £500,000 have to file audited financial statements within 9 months from their financial year-end.

    Companies with turnover of less than £500,000 have to file financial statement accompanied by an Independent Accountant's Report within 9 months from their financial year-end.

    Consolidated tax returns are not allowed.

    Tax Assessments

    The Commissioner has up to 6 months to issue a tax assessment.

  • CORPORATION TAX

    Corporation Tax

    Corporation tax is levied at a flat rate of 10%.

  • DIVIDENDS

    Dividends from Foreign Investments

    Dividend income of a Gibraltar company from foreign investments is exempt from tax in Gibraltar.

    Dividends from Local Investments

    Dividend income of a Gibraltar company from another Gibraltar company is exempt from tax in Gibraltar.

    Withholding Tax on Dividends

    Dividend payments by a Gibraltar company to a foreign shareholder (company or individual) does not suffer any withholding tax.

    Dividend payments by a Gibraltar company to another Gibraltar company does not suffer any withholding tax.

  • INTEREST

    Interest Income

    Interest income (except for banks) is not subject to tax in Gibraltar.

    However, following the conclusion of the EU Code of Conduct Group back in November 2012 that the intercompany interest tax treatment in Gibraltar is not in line with EU requirements, the Government of Gibraltar has approved amendments in this respect that will apply as of 1 July 2013. Under these amendments, interest received or receivable (more than GBP£100,000) from inter-company loans will be taxable in Gibraltar if the company receiving the interest is registered in Gibraltar.

    The new taxation rate of intercompany interest is:

    • 10% for inter-company interest above GBP£100,000.
    • 0% for inter-company interest less than GBP£100,000 unless the income falls within the scope of trading income (e.g. banks, building societies etc).

    Interest receivable or received from all group companies will be aggregated when determining the GBP£100,000 threshold.

    Interest Expense Deductibility

    Interest expense is tax-deductible only if incurred wholly and exclusively for the production of taxable income.

    Withholding Tax on Interest

    Gibraltar does not impose any withholding tax on payments to foreign recipients.

    There is no withholding tax on the payment of interest by one Gibraltar Company to another Gibraltar company.

  • ROYALTIES

    Royalty Income

    With effect from 1 January 2014, income from royalties received or receivable by a Gibraltar company is taxable at the standard corporation tax rate.

    Royalty Expense Deductibility

    Royalty expense is tax-deductible only if incurred wholly and exclusively for the production of taxable income.

    Withholding Tax on Royalties

    Gibraltar does not impose any withholding tax on royalty payments to foreign recipients.

  • TAX LOSSES

    Ordinary Tax Losses

    Ordinary tax losses can be carried forward indefinitely and be set-off against taxable income of future years.

    The right to carry forward tax losses is lost in the event of an ownership change in a Gibraltar company and a substantial change in the business of that company within a 3 year period.

    There is no carry back of ordinary tax losses.

    Group Relief

    There are no group taxation provisions in the tax legislation of Gibraltar.

  • CAPITAL GAINS

    Disposal of Shares by Foreign Shareholder

    The disposal of shares of a Gibraltar company by its foreign shareholder is not subject to tax in Gibraltar provided that it does not hold Gibraltar real estate (in such a case stamp duty may apply - see below).

    Capital Gains

    Capital gains are not subject to tax in Gibraltar.

    Capital Losses

    Not tax-deductible since capital gains are not taxable.

  • PARTNERSHIPS

    Partnership Profits

    General and Limited partnerships are treated as transparent entities for tax purposes which means that their profits are taxed directly in the hands of each partner.

  • BRANCHES

    Branch Profits

    The profit of a Gibraltar Branch generated in Gibraltar is taxed under Gibraltar income tax at the rate of 10%.

    There is no tax in Gibraltar on the remittance of the profit of a Gibraltar Branch to its foreign head office.

  • STAMP DUTY

    Stamp Duty

    Stamp duty is imposed on the purchase of real estate or shares in a company owning Gibraltar real estate.

    Stamp duty on share capital and loan capital is fixed at GBP£10.

    The following rates apply for the purchase of real estate or shares in companies owning Gibraltar real estate:

    Consideration Rate
    Below £200,000 Nil
    £200,000 - £350,000 - 2% on first £250,000
    - 5.5% on next £100,000
    Above £350,000 - 3% on first £350,000
    - 3.5% on excess
  • CAPITAL DUTY

    Capital Duty

    Capital duty of £10 is imposed on the initial issue or any subsequent increases of authorized share capital.

  • VAT

    There is no VAT in Gibraltar.