🇼🇸 Samoa

Samoa international companies (International Company) currently still benefit from a 0% effective tax rate on foreign-source income, but under the exemption-repeal amendment enacted in January 2026, from 1 January 2028 a territorial system will apply, with Samoa-source income subject to 27% corporate tax. Samoa was removed from the EU list of non-cooperative tax jurisdictions on 17 February 2026 (the entity still on the list is American Samoa). Taiwanese persons investing in mainland China through a Samoa company must still apply to the Ministry of Economic Affairs for approval or file as required.

Samoa Key conditions at a glance

Samoa 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.
• Taiwanese persons who hold more than 10% of the shares, or serve as directors/supervisors or managers, and then invest in mainland China through a Samoa company, are engaged in 'investment in the mainland area' and must first apply to the Ministry of Economic Affairs for approval or file a report in accordance with the applicable threshold.

What did Samoa's 2026 legislative amendment change? What is different before and after 2028?

A press release dated 18 February 2026 by the Samoa International Financial Authority (SIFA) confirmed that the Miscellaneous (Removal of Tax Exemption for International Companies) Amendment Act 2026 was enacted in January 2026; in its 17 December 2025 report on the bill, the Samoa Observer noted that the new regime includes a transition period, will be fully implemented in 2028, and that international companies will be subject to the same tax system as local enterprises.

According to rates published by the Samoa Ministry of Revenue, the corporate income tax rate is 27%. The new regime, as summarized by registered agents, is as follows: from 1 January 2028, Samoa-source income of international companies will be subject to 27%, while foreign-source income will retain a 0% effective tax rate. Transitional details (filing forms, arrangements for existing companies) are subject to SIFA's latest announcements.

Source: SIFA press release (2026-02-18): Samoa Welcomes Removal from the European Union Tax Blacklist

If a Taiwanese person invests in mainland China through a Samoa company, must a filing be made with the Ministry of Economic Affairs?

Yes. Under Article 3, Paragraph 2 of the Regulations Governing Permission for Investment or Technical Cooperation in the Mainland Area, where a Taiwanese person directly or indirectly invests in a third-territory company (e.g., a Samoa international company) and serves as a director, supervisor, manager or equivalent position of that company, or holds more than 10% of its shares, and that company establishes a company, increases capital, acquires equity or sets up a branch in mainland China, this constitutes 'investment in the mainland area'. The obligation is not eliminated merely because the investment is made indirectly through a Samoa company.

Procedurally (Articles 6, 8 and 10 of the same Regulations): in principle, prior approval from the Ministry of Economic Affairs is required; where the cumulative investment amount for an individual case is below the threshold announced by the Ministry of Economic Affairs, filing may be made instead, and filing must be completed within 6 months after implementation; if capital or earnings from the mainland invested enterprise are subsequently repatriated, notification must be made within 1 month after repatriation.

Without approval or filing, under Article 86 of the Act Governing Relations Between the People of the Taiwan Area and the Mainland Area, general category items may be subject to a fine of not less than NT$50,000 and not more than NT$25,000,000, and an order may be issued to cease or rectify within a specified period. This paragraph is based on the 2024-08-08 amended version of the Regulations as set out in the Laws and Regulations Database and verified by this site on 2026-09-12; filing thresholds and forms are subject to the latest announcements of the Investment Review Department, Ministry of Economic Affairs.

Source: Laws and Regulations Database — Regulations Governing Permission for Investment or Technical Cooperation in the Mainland Area

After Samoa switches to a territorial system in 2028, will Taiwan's CFC rules still apply?

Very likely still yes. Article 43-3 of Taiwan's Income Tax Act provides two definitions of a 'low-tax country or region': the corporate tax rate does not exceed 70% of Taiwan's rate (i.e., 14%), or it taxes only domestic-source income. Samoa's territorial system from 2028 taxes only Samoa-source income at 27% and maintains foreign-source income at 0%; under the statutory definition, this still constitutes taxation only on domestic-source income.

Therefore, where a Taiwan profit-seeking enterprise and its related parties together hold 50% or more of an affiliated Samoa enterprise, or have significant influence over it, unless the company has substantive operating activities locally, or its current-year earnings are below the threshold prescribed by the Ministry of Finance, investment income must be recognized in Taiwan in proportion to the shareholding even if earnings are not distributed; individuals are separately subject to individual CFC rules under Article 12-1 of the Income Basic Tax Act.

If a Taiwan company, having obtained approval, invests in mainland China through a Samoa company, under Article 24, Paragraph 2 of the Act Governing Relations Between the People of the Taiwan Area and the Mainland Area, the portion of the Samoa company's investment income derived from mainland re-investment is deemed mainland-area source income and included in taxable income; income tax already paid in mainland China and third territories may be credited within the prescribed limit. Actual application is subject to a case-by-case determination by the National Taxation Bureau.

Source: Laws and Regulations Database — Article 43-3 of the Income Tax Act (profit-seeking enterprise CFC, low-tax jurisdiction definition)

Samoa Application process

1. Establish an international company through a licensed registered agent.
2. Register UBO and appoint a director.
3. Open a bank account and prepare KYC documents.
4. Pay attention to territorial transition regulations and pay annual fees to maintain it.

Official sources: Samoa International Finance Authority (SIFA) · Data date: 2026-09-12.This page is a neutral compilation of public data, for reference only, not tax/legal advice; options are subject to the latest official announcements.

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