Fiji Cross-Border Tax Guide 2026

Overview — Cross-Border Taxation in Fiji

Fiji's cross-border tax rules are governed by the Income Tax Act 2015, the Tax Administration Act, and various double tax treaties. The Fiji Revenue and Customs Service (FRCS) has been strengthening its international tax capacity, including participation in the OECD's Base Erosion and Profit Shifting (BEPS) Inclusive Framework. Multinational enterprises operating in Fiji must comply with transfer pricing documentation requirements and withholding tax obligations. Non-residents earning Fiji-source income are generally subject to withholding taxes at statutory rates, which may be reduced under applicable treaties. Fiji has a limited treaty network, with comprehensive DTTs with Australia, New Zealand, and the United Kingdom.

Double Tax Treaties — Australia, New Zealand, UK

Fiji has three comprehensive double tax treaties currently in force:

• Australia — The Fiji-Australia DTT provides for reduced withholding tax rates: 10% on dividends (5% for 10%+ shareholding), 10% on interest, and 10% on royalties. The treaty follows the OECD Model and includes a permanent establishment threshold of 183 days for services.
• New Zealand — The Fiji-New Zealand DTT provides withholding tax rates: 15% on dividends (5% for 10%+ shareholding), 10% on interest, and 10% on royalties. The treaty includes exchange of information provisions and mutual agreement procedures.
• United Kingdom — The Fiji-UK DTT provides: 15% on dividends (5% for 10%+ shareholding), 10% on interest, and 10% on royalties. The treaty includes a non-discrimination clause and limitation of benefits provisions.

To claim treaty benefits, the non-resident must provide a Certificate of Tax Residency from their home country and submit a treaty relief application to FRCS. Treaty benefits include reduced withholding tax rates and potential exemption from certain Fiji taxes.

Withholding Taxes to Non-Residents

Payments to non-residents from Fiji-source income are subject to withholding tax at the following standard rates (treaty rates may apply):

• Dividends — 15% (reduced to 5–10% under DTTs)
• Interest — 10% (reduced to 10% under most DTTs)
• Royalties — 15% (reduced to 10% under DTTs)
• Management & technical fees — 15%
• Branch profits remittance — 0% (no branch remittance tax)

The person making the payment must withhold the tax and remit it to FRCS within 15 days. A withholding tax certificate must be issued to the non-resident.

Transfer Pricing

Fiji's transfer pricing rules follow the OECD Transfer Pricing Guidelines. The regulations require that transactions between related parties be priced at arm's length. Related parties include companies under common control, parent-subsidiary relationships, and individuals with significant influence. Documentation requirements include contemporaneous documentation demonstrating that transfer prices are arm's length. Acceptable transfer pricing methods include the Comparable Uncontrolled Price (CUP) method, Cost Plus method, Resale Price method, Transactional Net Margin Method (TNMM), and Profit Split method. Advance Pricing Agreements (APAs) are available for qualifying taxpayers. Penalties for non-compliance range from 25% to 100% of the tax adjustment plus interest.

Fiji-Source Income Rules

Non-residents are taxed only on income derived from sources in Fiji. The Income Tax Act defines specific source rules:

• Employment income — sourced where employment duties are performed
• Business income — sourced where business activities are carried out (or through a permanent establishment in Fiji)
• Property income — sourced where the property is located
• Dividends — sourced where the paying company is resident
• Interest — sourced where the payer is resident
• Royalties — sourced where the intellectual property is used

Income sourced in Fiji by a non-resident is subject to withholding tax at the applicable rate, which may be reduced under a double tax treaty.

FAQs

Do I need to register for tax in Fiji as a non-resident investor?

Non-residents earning Fiji-source income subject to final withholding tax generally do not need to register. However, a non-resident with a permanent establishment in Fiji must register and file corporate tax returns.

How do I claim treaty benefits in Fiji?

Submit a Treaty Relief Application to FRCS with a Certificate of Tax Residency from your home country. The application must be submitted before or at the time of the first payment. Approved applications are valid for up to 3 years.

Does Fiji have a General Anti-Avoidance Rule (GAAR)?

Yes, the Income Tax Act includes a GAAR that allows FRCS to recharacterise transactions entered into for tax avoidance purposes. The GAAR applies to both domestic and cross-border arrangements.

Disclaimer

This guide provides general information about Fijian cross-border taxation for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Fijian international tax advisor or the Fiji Revenue and Customs Service for advice specific to your situation. InvestmentKit does not provide tax advice.