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  • Writer's picturePoevai Garnier

Media Release - New criteria introduced for determining Company Tax Residence

Changes to residency test for Cook Islands companies. The Cook Islands has recently amended provisions of the Income Tax Act 1997 to change the tax residency test for companies; such changes are consistent with international tax policy and the OECD BEPS requirements. Prior to these changes, a company was considered to be tax resident in the Cook Islands if it was incorporated there it or it had its centre of administrative management there. Under the new law, the tests for whether a company is resident in the Cook Islands are: if the directors of the company exercise control in the Cook Islands or, the place of effective management is in the Cook Islands or, if the company is a Cook Islands company and at any moment in time during the income year, 3 or more of its directors are resident in the Cook Islands. Check out the full media release here :

See here for legislation:

Income Tax (Company Residence) Amendment Act 2021 No.17
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