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9.1. Unilateral and Treaty Based Methods Available for the Elimination or Mitigation of Double Taxation

Resident taxpayers are entitled to a credit for foreign taxes paid on income earned outside Kiribati against the tax liability in Kiribati, which is limited to the amount of Kiribati tax applicable to such foreign income. For the purposes of the foreign tax credit, the Kiribati income tax on any foreign income shall be calculated by applying the average rate of Kiribati income tax to any income derived from a foreign source, reduced by any deduction allocated to that income.

Below is a summary of the available methods for various income tax streams based on domestic law.

Royalty Copyright OC
Capital Gains OC
Dividends OC
Interest OC
Royalty Patent OC
Sales OC
Service Management OC
Service Technical OC
Royalty Trademark OC

The credit column shows the type of foreign tax credit granted when the receiving country receives a payment.  Four abbreviations are used for the type of foreign tax credit available:

  • NC means no credit but foreign withholding taxes can be deducted.
  • OC means ordinary credit, i.e., credit for foreign withholding taxes (e.g., withholding taxes).
  • IC means indirect credit, i.e., credit for underlying corporate taxes as well as foreign withholding taxes.
  • ND means no credit and no deduction for any foreign withholding taxes incurred.