Why Gibraltar
How does the Gibraltar tax system work?
Gibraltar levies corporation tax at 15% on a territorial basis. There is no capital gains tax, general VAT regime, wealth tax or inheritance tax; Transaction Tax applies to relevant goods. Stamp duty applies to Gibraltar property and certain unquoted investments in property-owning entities, including indirect holdings. Category 2 and HEPSS have distinct personal tax rules.
Corporation tax
15% territorial corporation tax
The Income Tax Act 2010 is the principal statute governing taxation in Gibraltar. Corporation tax applies to companies at a rate of 15%, but only on the territorial portion of profits.
The territorial principle
Gibraltar taxes profits that accrue in or are derived from Gibraltar. This is determined by the source of the income — specifically, where the underlying activity, service, or income-generating event takes place. A company incorporated in Gibraltar but conducting its trading operations in the United Kingdom, Germany, or the United States will not be subject to Gibraltar corporation tax on those trading profits. The income is sourced outside Gibraltar and falls entirely outside the Gibraltar tax base.
What is in scope
Income sourced in Gibraltar includes: remuneration for services physically performed in Gibraltar, rental income from Gibraltar property, profits from trading activities conducted in Gibraltar, and management fees charged by a Gibraltar-based manager for services rendered in Gibraltar. A Gibraltar company providing management or advisory services from Gibraltar will typically be taxable on those fees at 15%. The analysis of source requires a facts-and-circumstances assessment of where the value-generating activity occurs. A higher 20% rate applies to utility, energy and fuel suppliers and to companies that abuse a dominant market position.
No capital gains tax
Gibraltar has no capital gains tax. Gains on disposal of any asset — shares, real estate, intellectual property, cryptocurrency, business interests — are not subject to any Gibraltar tax, whether the asset is Gibraltar-sited or located offshore. This applies to individuals and companies alike. There is no equivalent of the UK's section 1 TCGA 1992 charge in Gibraltar.
Stamp duty and Gibraltar property
Under the Stamp Duties Act 2005, instruments involving Gibraltar real property or certain unquoted investments in bodies holding it may be chargeable, including where the interest is indirect. Section 24(7) addresses the property-value basis when other assets are also held. A share sale is not an automatic exemption for Gibraltar real estate; the instrument, ownership chain, exemptions and anti-avoidance rule all matter.
Taxes not levied
What Gibraltar does not tax
The absence of several major tax heads makes Gibraltar materially different from European high-tax jurisdictions and from the UK.
VAT and Transaction Tax
Gibraltar has no VAT or GST regime and does not require VAT returns. Transaction Tax applies to relevant goods from 15 July 2026; it is not a general services VAT. Cross-border supplies may have tax consequences in the destination jurisdiction.
No wealth tax
Gibraltar levies no wealth tax on individuals or companies. There is no annual charge on asset holdings, net worth, or financial assets. This makes Gibraltar attractive for high-net-worth individuals who might otherwise face wealth taxes in jurisdictions such as Spain (whose solidarity tax applies to non-residents holding Spanish assets), Switzerland (cantonal wealth tax), or Norway (net wealth tax at 1.1%).
No inheritance tax
Gibraltar has no inheritance tax, estate duty, or gift tax. Transfers of assets on death — including shares in Gibraltar companies, Gibraltar real estate, and moveable assets held in Gibraltar — are not subject to any Gibraltar death duty. This is a material advantage for estate and succession planning for non-domiciliaries, particularly those with UK connections where HMRC inheritance tax at 40% applies to worldwide estates above the nil-rate band.
No withholding tax on dividends
Gibraltar does not impose withholding tax on dividend distributions made by Gibraltar companies to non-resident shareholders. A Gibraltar company can repatriate profits to its shareholders — wherever resident — without deducting any Gibraltar withholding tax. The recipient's home jurisdiction may impose tax on receipt of dividends depending on its domestic rules and applicable tax treaties.
Personal tax
Cat 2 and HEPSS personal tax regimes
Gibraltar offers two special personal income tax regimes for qualifying residents: Category 2 (high net worth individuals) and HEPSS (senior executives with specialist skills).
Category 2 Individual
Under the Category 2 Rules, rates apply to the first £118,000 of taxable income, with a £37,000 full-year minimum; rule 10 separately addresses Gibraltar property income and permitted local activity. LN 2026/127 raised the application fee to £5,000 from 22 June 2026. Separately, the Government announced a £5 million minimum-net-wealth policy for new applicants and grandfathering for existing holders. The Rules leave financial standing to the Finance Centre Director, so confirm the published policy and application evidence with the Finance Centre.
HEPSS — High Executive Possessing Specialist Skills
HEPSS is a personal tax concession for senior employees or executives possessing skills not available locally in Gibraltar. Under HEPSS, income above £160,000 per annum is exempt from Gibraltar income tax. The individual is taxed at normal Gibraltar rates only on the first £160,000 of qualifying employment income. HEPSS requires an application to and approval by the Commissioner of Income Tax, supported by evidence that the skills are genuinely specialist and not locally available. It must be renewed annually and is typically sought by senior executives relocating to Gibraltar with regulated firms.
Standard personal income tax
For individuals who do not qualify for Cat 2 or HEPSS, Gibraltar operates a standard progressive income tax with two allowance-based systems — the Allowances Based System (ABS) and the Gross Income Based System (GIBS). Under ABS, individuals claim personal allowances and pay tax on net assessable income. Under GIBS, tax is calculated on gross income at reduced rates. Individuals elect annually which system to apply. The maximum marginal rate under the standard system is approximately 28%, materially lower than the UK's 45% additional rate.
International compliance
DTA with UK, CRS, and FATCA
Gibraltar meets international tax transparency standards as a participating jurisdiction under CRS and as an IGA partner under FATCA.
Gibraltar–UK Double Taxation Agreement
The Gibraltar–UK DTA provides a framework for eliminating double taxation for individuals and entities with cross-border connections to both jurisdictions. It covers income tax, corporation tax, and associated charges. Key provisions deal with the allocation of taxing rights over employment income, dividends, interest, royalties, and capital gains. The DTA is relevant for Gibraltar-resident individuals with UK-source income, Gibraltar companies with UK operations or UK directors, and cross-border structures involving both jurisdictions. The DTA is the only full double tax agreement Gibraltar has concluded.
Common Reporting Standard (CRS)
Gibraltar has been a CRS participating jurisdiction since 2017. Gibraltar financial institutions — banks, investment firms, fund administrators, trustees, and corporate service providers acting as financial institutions — must identify account holders who are tax-resident in CRS partner jurisdictions, collect the required due diligence information, and make annual reports to the Gibraltar Commissioner of Income Tax. The Commissioner exchanges this information automatically with the tax authorities of partner jurisdictions. Gibraltar participates in the multilateral competent authority agreement (MCAA).
FATCA
Gibraltar signed a Model 1 Intergovernmental Agreement (IGA) with the United States in 2013. Under the Model 1 IGA, Gibraltar financial institutions report information on US persons to the Gibraltar Commissioner of Income Tax, who transmits the data to the US Internal Revenue Service. Gibraltar financial institutions must register with the IRS FATCA portal as reporting foreign financial institutions. Non-compliant entities risk withholding on US-source payments. Resilience Group's compliance services include FATCA classification and reporting support for Gibraltar-regulated entities.
Common questions
Gibraltar tax — FAQs
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What taxes does Gibraltar not have?
Gibraltar has no general VAT regime, capital gains tax, wealth tax or inheritance tax. Transaction Tax applies to relevant goods from 15 July 2026. Stamp duty and withholding questions depend on the instrument, property and payer; seek advice on the specific transaction.
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How does Gibraltar's territorial tax system work for companies?
Gibraltar corporation tax at 15% applies only to profits accruing in or derived from Gibraltar. The source of income is determined by where the underlying activity takes place. A Gibraltar company trading offshore, earning foreign investment income, or holding overseas property will not be subject to Gibraltar corporation tax on those profits — regardless of where the company is incorporated or registered.
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Does Gibraltar have a tax treaty with the UK?
Yes. Gibraltar and the UK have a Double Taxation Agreement covering income tax, corporation tax, and related charges. The DTA allocates taxing rights between the two jurisdictions and provides relief from double taxation for individuals and entities with cross-border connections. It is Gibraltar's only comprehensive double tax agreement. Individuals and entities with both Gibraltar and UK tax connections should take specific advice on DTA application.
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What is the Category 2 Individual tax regime?
Category 2 applies rates to the first £118,000 of taxable income, subject to rule 10 treatment for Gibraltar property income and permitted local activity, with a £37,000 full-year minimum. The 2026 amendment set the £5,000 application fee from 22 June. The Government separately announced a £5 million net-wealth criterion for new applicants and grandfathering for existing holders. The Finance Centre Director issues certificates; check current policy and individual eligibility.
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What is the HEPSS regime and who qualifies?
HEPSS — High Executive Possessing Specialist Skills — exempts income above £160,000 per annum from Gibraltar income tax for qualifying senior executives. The individual is taxed only on the first £160,000 of employment income at standard Gibraltar rates. Qualification requires evidence of specialist skills not available locally in Gibraltar and annual renewal with the Commissioner of Income Tax. HEPSS is typically used by senior executives relocating to Gibraltar with regulated financial services firms.
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Is Gibraltar compliant with CRS and FATCA?
Yes. Gibraltar has been a CRS participating jurisdiction since 2017 and has a Model 1 IGA with the United States for FATCA purposes. Gibraltar financial institutions must identify reportable account holders, collect due diligence information, and report annually to the Gibraltar Commissioner of Income Tax, who exchanges information with partner jurisdictions. Resilience Group provides FATCA classification and CRS reporting support for Gibraltar-regulated entities and structures.
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Is there stamp duty on Gibraltar property or share transactions?
Stamp duty can apply to Gibraltar real property and certain unquoted investments in property-owning entities, including indirect interests. A sale of shares in a property-holding company is not automatically free of duty. The Stamp Duties Act 2005 determines the charge, property-value basis, exemptions and anti-avoidance treatment for each instrument.
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Gibraltar tax compliance, financial statement preparation, and corporate tax filing for Gibraltar-registered entities.
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Cat 2 and HEPSS applications, residency documentation, and ongoing compliance for Gibraltar-based individuals.
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Gibraltar Companies Act, incorporation timelines, and corporate governance requirements.
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Need Gibraltar tax compliance or advice?
Resilience Group provides Gibraltar tax compliance services for companies and individuals, including corporate tax filings, CRS/FATCA reporting, and Cat 2 and HEPSS application support. We work directly with clients and their tax advisers.
