🇬🇮 Gibraltar
Europe & Central Asia ·
Gibraltar maintains statutory controlled foreign company rules and interest limitation rules. The jurisdiction also requires statutory country-by-country reporting.Auto-generated summary of the verified data below; every fact traces to a source on this page.
5/11
enforcement powers assessed
Headline statutory rates
As stated in PwC Worldwide Tax Summaries’ territory overview (fetched 2026-08-20) — the wording is PwC’s; source.
| Tax | Headline rate as stated |
|---|---|
| Headline PIT rate | Lower of the Allowances Based system (14% - 39%) and Gross Income Based system (6% - 28%). Maximum effective tax rate of 25%. |
| Headline CIT rate | 15% from 1 July 2024 (12.5% up to 30 June 2024). Utility and energy providers and corp.'s abusing a dominant position pay a rate of 20%. |
| Standard VAT rate | NA |
| Headline individual capital gains tax rate | NA |
| Headline corporate capital gains tax rate | NA |
| WHT rates (%) (Dividends/Interest/Royalties) | NA |
| Headline net wealth/worth tax rate | NA |
| Headline inheritance tax rate | NA |
| Headline gift tax rate | NA NA stands for Not Applicable (i.e. the territory does not have the indicated tax or requirement) NP stands for Not Provided (i.e. the information is not currently provided in this chart) |
Enforcement powers
Crypto-asset reporting Partial / committed
Listed by the OECD Global Forum as committed to implement the Crypto-Asset Reporting Framework in time for first exchanges by 2027 (list updated 17 June 2025).
“Germany, Gibraltar, Greece”
Source: OECD Global Forum — Jurisdictions committed to implement the Crypto-Asset Reporting FrameworkOfficial source · quote machine-verified 2026-08-25
Citizenship-based taxation No — power absent
Gibraltar taxes individuals by residence, not citizenship (PwC Worldwide Tax Summaries).
“Income tax is also charged on certain income accruing in, derived from, or received in any place other than Gibraltar by any person ordinarily resident in Gibraltar.”
Source: PwC Worldwide Tax Summaries — GibraltarProfessional / legal analysis · quote machine-verified 2026-08-25
Controlled foreign company (CFC) rules Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Interest limitation rules Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Regime 1" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Country-by-country reporting Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).
“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 7 data points
| Is there a controlled foreign company rule in place? · Not applicable | Yes |
| Controlled foreign company rule · Not applicable | controlled foreign company shall mean an entity or a permanent establishment, not resident in Gibraltar, whose profits are not taxable or are exempt from tax in Gibraltar when the following conditions are simultaneously fulfilled: (a) in the case of an entity, the taxpayer by itself, or together with its associated enterprises: (i) holds a direct or indirect participation of more than 50 percen… |
| Significant controlled foreign company exemption and exclusion requirements · Not applicable | Rules do not apply to a CFC with accounting profits of no more than 750,000, and non-trading income of no more than 75,000; or (b) of which the accounting profits amount to no more than 10% of its operating costs for the tax period. |
| Controlled foreign company income · Not applicable | The income of the controlled foreign company which is to be included as income of a taxpayer shall be limited to amounts generated through assets and risks which are linked to significant people functions carried out by the controlling company. |
| Substantial activity requirements · Not applicable | No |
| Trigger rate for controlled foreign company rule · Not applicable | One of the conditions that has to be met for CFC rules in Gibraltar to apply is as follows: the actual tax paid on its profits by the entity or permanent establishment is lower than the difference between the tax that would have been charged on the entity or permanent establishment in accordance with this Act and the actual tax paid on its profits by the entity or permanent establishment. The head… |
| Year of introduction of the controlled foreign company rule · Not applicable | 43466 |
Interest limitation — 39 data points
| Number of years allowed under carry forward/back. · Regime 1 | 5 years |
| Number of years allowed under carry forward/back. · Rule 1 | 5 years |
| Do any loss carry-back or carry-forward provisions apply? · Regime 1 | Yes |
| Do any loss carry-back or carry-forward provisions apply? · Rule 1 | Yes |
| Is a de minimis threshold present? · Regime 1 | 3000000 |
| Is a de minimis threshold present? · Rule 1 | EUR 3 million |
| Any other exclusions? · Regime 1 | Yes |
| Any other exclusions? · Rule 1 | Yes |
| Exclusions based on payer characteristics? · Regime 1 | No |
| Exclusions based on payer characteristics? · Rule 1 | No |
| Exclusions based on payment characteristics? · Regime 1 | No |
| Exclusions based on payment characteristics? · Rule 1 | No |
| Exclusions based on recipient characteristics? · Regime 1 | No |
| Exclusions based on recipient characteristics? · Rule 1 | No |
| Financial accounting measure applied to rule · Regime 1 | interest-to-EBITDA |
| Financial accounting measure applied to rule · Rule 1 | interest-to-EBITDA |
| Description of group ratio rule · Regime 1 | Where a taxpayer is a member of a consolidated group for financial accounting purposes, the taxpayer may choose to either: (a) fully deduct its exceeding borrowing costs if it can demonstrate that the ratio of its equity over its total assets is equal to or higher than the equivalent ratio of the group and subject to the following conditions: (i) the ratio of the taxpayer s entity over its total a… |
| Description of group ratio rule · Rule 1 | Where a taxpayer is a member of a consolidated group for financial accounting purposes, the taxpayer may choose to either: (a) fully deduct its exceeding borrowing costs if it can demonstrate that the ratio of its equity over its total assets is equal to or higher than the equivalent ratio of the group and subject to the following conditions: (i) the ratio of the taxpayer’s entity over its total a… |
| Is there a group ratio rule or similar type of rule in place? · Regime 1 | Yes |
| Is there a group ratio rule or similar type of rule in place? · Rule 1 | Yes |
| Is there an interest limitation rule in place? · Regime 1 | Yes |
| Is there an interest limitation rule in place? · Rule 1 | Yes |
| Can interest be recharacterised as a dividend? · Regime 1 | No |
| Can interest be recharacterised as a dividend? · Rule 1 | No |
| Is the rule is applicable to net or gross interest expensing? · Regime 1 | 3000000 |
| Is the rule is applicable to net or gross interest expensing? · Rule 1 | €3,000,000 |
| Is the rule applicable to related party debt? · Regime 1 | Yes |
| Is the rule applicable to related party debt? · Rule 1 | Yes |
| Description of interest limitation rule · Regime 1 | Exceeding borrowing costs incurred by a taxpayer shall be deductible in the tax period in which they are incurred only up to the greater of the following two amounts: (a) 30% of the taxpayer s EBITDA; or (b) 3,000,000 (based on group). |
| Description of interest limitation rule · Rule 1 | Exceeding borrowing costs incurred by a taxpayer shall be deductible in the tax period in which they are incurred only up to the greater of the following two amounts: (a) 30% of the taxpayer’s EBITDA; or (b) €3,000,000 (based on group). |
| Type of interest limitation rule · Regime 1 | Fixed ratio rule |
| Type of interest limitation rule · Rule 1 | Fixed ratio rule |
| Financial ratio referenced · Regime 1 | 3:10 (i.e. 30%) |
| Financial ratio referenced · Rule 1 | 3:10 (i.e. 30%) |
| Is the rule is applicable to third party debt? · Regime 1 | Yes |
| Is the rule is applicable to third party debt? · Rule 1 | Yes |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 1 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 1 | No |
| Year of introduction of the interest limitation rule · Rule 1 | 2019 |
Country-by-country reporting — 4 data points
| Is there a country-by-country reporting law in place? | Yes |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | EUR 750 million |
| Headquarter jurisidiction filing required from | 01-Jan-16 |