🇼🇸 SamoaCompany Establishment/Offshore Registration Highlights
Samoa International Companies (International Company) have long been exempt from tax on foreign-sourced income, commonly used for holding. According to the 2026 amendment, the comprehensive tax exemption for international companies will be abolished starting January 1, 2028, transitioning to a territorial tax system (standard tax rate for domestic income, maintaining a 0% effective tax rate for foreign-sourced income). Samoa has been removed from the EU's non-cooperative list as of 2026. Regulatory changes are ongoing; please refer to the latest announcements from the Samoan authorities.
| Common Company Types | International Company (International Company) |
|---|---|
| Corporate income tax | 0% effective on foreign-sourced income; transitioning to a territorial basis (standard tax rate on domestic income) starting in 2028. |
| Estimated establishment costs | Approximately US$500–US$1,500 |
| Annual maintenance | Annual fee, registered agent, registered address. |
| Substance/Reporting Requirements | UBO, CRS; pure holding companies generally have no independent substance requirements; territorial reporting will be implemented |
| Suitable for purpose | Holding and Asset Management |
| Bank account opening | Offshore account opening is tightening, requiring comprehensive KYC. |
| Recent Changes | In 2026, legislative changes will eliminate the full tax exemption for international companies starting in 2028, transitioning to a territorial system; removal from the EU list will occur in 2026. |
Key considerations
- The tax exemption system will transition to a territorial basis starting in 2028, and existing structures should be assessed for transitional impacts in advance.
- Although there are no independent economic substance requirements for pure holding companies, compliance with UBO and information exchange requirements is still necessary.
- Home country CFC/substance taxation rules may still apply; should not be considered as overall tax exemption.
General Process
- Establish an international company through a licensed registered agent.
- Register UBO and appoint a director.
- Open a bank account and prepare KYC documents.
- Pay attention to territorial transition regulations and pay annual fees to maintain it.
Frequently Asked Questions
Can Samoa International Companies still enjoy tax exemption?
Currently, the effective tax rate on foreign-source income remains at 0%, but according to the 2026 amendment, the full tax exemption for international companies will be abolished starting in 2028, transitioning to a territorial system; it is advisable to confirm transitional arrangements before establishment.
Is Samoa still on the EU blacklist?
Samoa was removed from the EU's non-cooperative tax jurisdiction list as of February 2026, but the list and regulations may change again; please refer to official announcements.
Official sources：Samoa International Finance Authority (SIFA) · Data date：2026-06。This page serves as a neutral compilation of publicly available information for reference only, notTax / LegalRecommendations are based on the latest official announcements.