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DOUBLE TAXATION AGREEMENTS (“DTA”)

For international trade and investment, a Barbados entity can be utilised to reduce withholding tax or impart other taxation benefits through additional DTA’s to which Barbados is a party. Barbados presently has DTA’s with:

Austria (2008) Botswana (2005) Canada (1983)

CARICOM (1995) China (2000) Cuba (1999)

Finland (1989) Malta (2001) Mauritius (2004)

Mexico (2010) Netherlands (2008) Norway (1990)

Seychelles (2009) Sweden (1991) Switzerland (1954)

U.S.A. (1984) Venezuela (1998) U.K. (1970)

The Barbados Government is committed to expanding its Treaty Network with the signing of a DTA with Ghana in 2008 which has been signed by both parties but not yet ratified by the individual Governments. Treaties in negotiation include: Brazil, Luxembourg, India, Chile, Ireland, South Africa, Russia, Italy, Japan, and Nigeria.

*Many of Barbados’s double taxation treaties contain a limitation on benefits. The provision prohibits treaty benefits from being applied to companies that already benefit from a special tax regime or prevent non-residents of a treaty country from enjoying the benefits of the treaty. An example of an entity already benefiting from a special tax regime would be the Barbados International Business Company (“IBC”) which is taxed at the maximum tax rate of 2.5%

Country Dividends Interest Royalties IBCs Qualify*
Austria 5 or 15% 0 % 0 % Yes
Bahrain  0%  0%  0%  Yes
Botswana 5 or 12% 10% 10% Yes
Canada 15% 10% 10% No
CARICOM 0% 15% 15% Yes
China 5% 10% 10% Yes
Cuba 5 or 15% 5 or 15% 5% Yes
Czech Republic  5 or 15%  5%  5 or 15%  No
Finland 5 or 15% 5% 0 or 4% No
Iceland  5 or 15%  10%  5%  No
Malta 5 or 15% 5% 5% Yes
Mauritus 5% 5% 5% Yes
Mexico 5 or 15% 10% 10% Yes (Partial)
Netherlands 0 or 15% 0% 0% No
Norway 5 or 10% 5% 5% No
Panama  5%  5% or 7.5%  7.5%  No
San Marino  0% or 5%  5%  0%  Yes
Seychelles 5% 5% 5% Yes
Singapore  0%  0% or 12%  8%  Yes
Spain  0% or 5%  0%  0%  No
Sweden 5 or 10% 5% 5% No
Switzerland 35% 0% 0% Yes
United Kingdom 0 or 15% 15% 0 or 15% No
USA 5 or 15% 5% 5% Yes (Partial)
Venezuela 5 or 10% 5 or 15% 10% Yes

A Case Study

Barbados is a mature jurisdiction with an offshore insurance industry established since in 1983 with over 300 active insurance companies particularly captives which has been key in managing our risk program.The use of a Barbados IBC as a Treasury Centre (TC) to centralize or decentralize treasury management for multinationals is a well-established practice due to tax efficiency of DTA’s, mature banking...

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Company

The Axebridge Group 
The Grove, 21 Pine Road, Belleville,
St. Michael, BB11113, Barbados
+1 (246) 228-9886
info@axebridge.com

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