Income Tax (Avoidance of Double Taxation) (CARICOM) Act

Link to law: http://www.belizelaw.org/web/lawadmin/PDF%20files/cap056.pdf
Published: 2000

CAP. 56 INCOME TAX (AVOIDANCE OF DOUBLE TAXATION) (CARICOM) ACT BELIZE

INCOME TAX (AVOIDANCE OF DOUBLE TAXATION) (CARICOM)ACT

CHAPTER 56

REVISED EDITION 2000

SHOWING THE LAW AS AT 31ST DECEMBER, 2000.

This is a revised edition of the law, prepared by the Law Revision Commissioner

under the authority of the Law Revision Act, Chapter 3 of the Laws of Belize,

Revised Edition 1980 - 1990.

This edition contains a consolidation of the following laws - Page

ARRANGEMENT OF SECTIONS 3

INCOME TAX (AVOIDANCE OF

DOUBLE TAXATION) (CARICOM) ACT 3 Amendments in force as at 31st December, 2000.

BELIZE

INCOME TAX (AVOIDANCE OF DOUBLE TAXATION) (CARICOM)ACT

CHAPTER 56

REVISED EDITION 2000

SHOWING THE LAW AS AT 31ST DECEMBER, 2000.

This is a revised edition of the law, prepared by the Law Revision Commissioner

under the authority of the Law Revision Act, Chapter 3 of the Laws of Belize,

Revised Edition 1980 - 1990.

This edition contains a consolidation of the following laws - Page

ARRANGEMENT OF SECTIONS 3

INCOME TAX (AVOIDANCE OF

DOUBLE TAXATION) (CARICOM) ACT 3 Amendments in force as at 31st December, 2000.

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Income Tax (Avoidance of Double Taxation)(Caricom) [CAP. 56 3

[ ]

CHAPTER 56

INCOME TAX (AVOIDANCE OF DOUBLE TAXATION)

(CARICOM)

ARRANGEMENT OF SECTIONS

1. Short title.

2. Interpretation.

3. The Agreement to have the force of law in Belize.

4. Member States.

5. Competent Authority.

6. Regulations.

SCHEDULE I

SCHEDULE II

SCHEDULE III

CHAPTER 56

INCOME TAX (AVOIDANCE OF DOUBLE TAXATION)

(CARICOM)

[12th August, 1996]

1. This Act may be cited as the Income Tax (Avoidance of Double

Taxation) (Caricom) Act.

Short title.

13 of 1996.

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2. In this Act, unless the context otherwise requires:-

“Agreement” means the Agreement among the Governments of the

Member States of the Caribbean Community for the avoidance of

double taxation and the prevention of fiscal evasion with respect to taxes

on income, profits or gains and capital gains and for the encouragement

of regional trade and investment, signed in Barbados on 6th July, 1994,

as set out in Schedule I hereto;

“Minister” means the Minister for the time being responsible for Finance.

3. Notwithstanding any other law, but subject to the provisions of

this Act, the Agreement shall have the force of law in Belize.

4.-(1) For the purposes of the Agreement the Member States shall be

Barbados, Belize, Grenada, Jamaica, Saint Lucia and Trinidad and

Tobago.

(2) The Minister may, by Order published in the Gazette, declare that

a State has become, or has ceased to be, a Member State for the pur-

poses of subsection (1) above, and that State shall accordingly become,

or cease to be, a Member State from the date of the making of such an

Order.

5. The functions under the Agreement of a Competent Authority

shall be preformed in Belize by the Minister.

6.-(1) The Minister may make regulations for the better carrying out of

the objects and purposes of this Act and the Agreement.

(2) Any regulations made by the Minister under subsection (1) above

shall, as soon as may be after the making thereof, be laid before the Na-

tional Assembly and shall be subject to negative resolution.

The Agreement to

have the force of

law in Belize.

Member States.

Competent

Authority.

Regulations.

Schedule I.

Interpretation.

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SCHEDULE I

(Section 2)

AGREEMENT

AMONG

THE GOVERNMENTS OF THE MEMBER STATES OF

THE CARIBBEAN COMMUNITY FOR THE AVOIDANCE

OF DOUBLE TAXATION AND THE PREVENTION OF

FISCAL EVASION WITH RESPECT TO TAXES ON IN-

COME, PROFITS OR GAINS AND CAPITAL GAINS AND

FOR THE ENCOURAGEMENT OF REGIONAL TRADE

AND INVESTMENT

The Governments of the Member States of the Caribbean Community,

desiring to conclude an Agreement for the avoidance of double taxation

and the prevention of fiscal evasion with respect to taxes on income, profits

or gains and capital gains and for the encouragement of Regional Trade and

Investment:

Have agreed as follows:

Scope, Taxes and Definitions

Article 1

Scope of Agreement

This Agreement shall apply to any person who is a resident of a Mem-

ber State in respect of which it has entered into force in accordance with

Article 28.

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Article 2

Taxes Covered

1. This Agreement shall apply to taxes on income, profits or gains

and capital gains arising in a Member State in respect of which the Agree-

ment has entered into force in accordance with Article 28 and which are

listed in Schedule II.

However, a Member State which introduces taxes on income, prof-

its or gains and capital gains after the entry into force of this Agreement

shall, by notification to the Secretariat, list in Schedule II those taxes which

will be subject to this Agreement.

2. This Agreement shall also apply to any identical or substantially

similar taxes which are imposed by a Member State after the date of sig-

nature of this Agreement in addition to, or in place of, those referred to in

paragraph 1 of this Article.

3. The competent authorities of Member States shall notify all others

of any substantial change in their laws relating to the taxes which are the

subject of this Agreement, within three (3) months after such change.

Article 3

General Definitions

1. In this Agreement unless the context otherwise requires-

(a) the word “company” means a body corporate or any en-

tity which is treated as a body corporate for tax purposes;

(b) the term “competent authority” means the Minister responsi-

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Article 6

Income from Immovable Properly

1. Income from immovable property shall be taxable only in the

Member State in which such property is situated.

2. The term “immovable property” shall be construed in accordance

with the law of the Member State in which the property in question is situ-

ated. The term shall in any case include property accessory to immovable

property, livestock and equipment used in agriculture or forestry, rights to

which the provisions of general law respecting landed property apply, usu-

fruct of immovable property and rights to variable or fixed payments as

consideration for the working of, or the right to work, mineral deposits,

sources and other natural resources; but ships, boats and aircraft shall not

be regarded as immovable property.

3. The provisions of paragraph 1 of this Article shall apply to income

derived from the direct use, letting, or use in any other form of immovable

property.

4. The provisions of paragraphs l and 3of this Article shall apply to the

income from immovable property of an enterprise and to income from im-

movable property used for the performance of professional services.

Article 7

Capital Gains:

1. Except as otherwise provided in this Article, gains derived from the

alienation of real property situated in a Member State shall be taxed only in

that State.

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2. For the purposes of this Article real property includes-

(i) immovable property referred to in Article 6;

(ii) shares or similar rights in a company, the assets of which

consist wholly or principally of immovable property; and

(iii) an interest in a partnership, trust or estate, the assets of

which consist wholly or principally of immovable property.

3. Gains derived by an enterprise of a Member State from the

alienation of ships, aircraft, or containers operated in international traffic

shall be taxable only in that Member State.

4. Gains from the alienation of property other than property re-

ferred to in paragraphs 1 and 3 shall be taxable only in the Member

State in which the gains arise.

Article 8

Business Profits

1. Profits resulting from business activities shall be taxable only by

the Member State wherein such business activities are undertaken.

2. A business enterprise shall be regarded as undertaking activities in

the territory of a Member State when it has in such Member State any of,

but not limited to, the following:

(a) an office, or place of business management;

(b) a factory, plant, industrial workshop or assembly shop;

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(c) a construction project in progress;

(d) a place or facility wherein natural resources are extracted

or exploited, such as a mine, well, quarry, plantation or fishing

boat;

(e) an agency, or premises, for the purchase or sale of goods;

(f) a depository, storage facility, warehouse or any similar es-

tablishment used for receiving, storing or delivering goods;

(g) any other premises, office or facilities, the purposes of

which are preparatory or auxiliary to the business activi-

ties of the enterprise;

(h) an agent or representative.

3. In determining the profits from a business activity there shall be al-

lowed as deductions expenses which are incurred for the purposes of that

activity in accordance with the laws of the Member State in which such

activity is undertaken.

4. Where an enterprise carries on business activities in more than one

Member State, each State may tax profits from sources within its territory.

If the activities are undertaken through representatives, or through the use

of facilities such as those indicated in paragraph 1 of this Article, the profits

earned shall be attributed to such representatives or facilities provided that

such representatives or facilities are totally independent from the business

enterprise.

5. Where the business profits include items of income which are dealt

with separately in other Articles of this Agreement, the provisions of those

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Articles shall, except as otherwise provided therein, supersede the provi-

sions of this Article.

Article 9

Shipping and Air Transport

1. Profits derived by an enterprise of a Member State from the op-

eration of ships or aircraft in international traffic shall be taxable only in

that Member State.

2. Profits derived from the operation of ships or aircraft used princi-

pally to transport passengers or goods exclusively between places in a

Member State shall be taxed only in that State.

3. The provisions of paragraph 1 of this Article shall also apply to

profits derived by an enterprise of a Member State from the participation

in a pool, a joint business or in an international operating agency.

4. For the purposes of this Article, profits from the operation of ships

or aircraft in international traffic include profits derived from the rental of

ships or aircraft if operated in international traffic by the lessee.

5. Profits of an enterprise of a Member State from the use, mainte-

nance or rental of containers (including trailers, barges and related equip-

ment for the transport of containers) shall be taxable only in that State to

the extent that such containers are used for the transport of goods or mer-

chandise in international traffic.

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Article 10

Associated Enterprises

Where-

(a) an enterprise of a Member State participates directly or

indirectly in the management, control or capital of an en-

terprise of another Member State; or

(b) the same persons participate, directly or indirectly in the

management, control or capital of an enterprise of a Mem-

ber State and an enterprise of another Member State;

and in either case conditions are made or imposed between the enterprises

in their commercial or financial relations which differ from those which would

be made between independent enterprises, then any profits which would,

but for those conditions, have accrued to one of the enterprises, but, by

reason of those conditions, have not so accrued, may be included in the

profits of that enterprise and taxed accordingly.

Article 11

Dividends

1. Dividends paid by a company which is a resident of a Member State

to a resident of another Member State shall be taxed only in the first-men-

tioned State.

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2. The rate of tax on the gross dividends shall be zero per cent.

3. The provisions of paragraph 1 of this Article shall not affect the

taxation of the company in respect of the profits out of which the divi-

dends are paid.

4. In this Article, the word “dividends” means income from shares,

mining shares, founders’ shares or other rights, not being preference shares

or debt claims, participating in profits, as well as income from other cor-

porate rights which is subjected to the same taxation treatment as income

from shares by the laws of the State of which the company making the

distribution is a resident.

5. The rate of tax on gross dividends from preference shares shall

not exceed the rate specified in Article 12.

Article 12

Interest

1. Interest arising in a Member State and paid to a resident of another

Member State shall be taxed only by the first-mentioned State.

2. The rate of tax shall not exceed fifteen per cent of the gross

amount of the interest.

3. Notwithstanding the provisions of paragraphs l and 2 of this Article,

interest derived from sources within a Member State shall be exempt from

tax in that Member State if it is beneficially owned by the Government of

another Member State, or by an agency or other entity of that Govern-

ment.

4. For the purpose of this Article, interest shall be deemed to arise in

the Member State where the payer is that State itself, a political subdivi-

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sion, a local authority or a resident of that State. However, where the

person paying the interest carries on business through an office, branch or

agency in a Member State, and such interest is borne by that office, branch

or agency, such interest shall be deemed to arise in the Member State in

which the office, branch or agency is situated.

5. Where, owing to a special relationship between the payer and the

recipient of the interest or between both of them and some other person,

the amount of the interest paid, having regard to the debt-claim in respect

of which it is paid, exceeds the amount which would have been agreed

upon by the payer and the recipient in the absence of such relationship,

the provisions of this Article shall apply only to the last-mentioned

amount. In that case, the excess part of the payment shall remain taxable

according to the laws of the Member State in which the interest shall be

deemed to arise.

6. In this Article, the word “interest” means income from debt-claims

of every kind, whether or not secured by mortgage and whether or not

carrying a right to participate in the debtor’s profits, and in particular, in-

come from government securities and income from bonds or debentures,

including premiums and prizes attaching to such securities, bonds or de-

bentures. Penalty charges for late payment shall not be regarded as inter-

est for the purpose of this Article.

7. The word “interest” shall not include any item of income which is

treated as a distribution by the tax laws of a Member State.

Article 13

Royalties

1. Royalties arising in a Member State and paid to a resident of another

Member State shall be taxed only in the first-mentioned State.

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2. The rate of tax shall not exceed fifteen per cent of the gross amount

of the royalties.

3. In this Article, the word “royalties” means payments of any kind

received as consideration for the use of, or the right to use any copyright

of literary, artistic or scientific work, including cinematograph films and

films or tapes of radio or television broadcasting, any patent, trademark,

design or model, plan, secret formula or process or other like property or

rights, or for the use of or the right to use industrial, commercial or scien-

tific plant or equipment, or for information concerning industrial, commer-

cial or scientific experience; but does not include royalties or other amounts

paid in respect of the operations of mines or quarries or in respect of the

extraction or removal of natural resources.

4. Royalties shall be deemed to arise in a Member State in which the

copyright, patent, trade mark, design, model, plan, secret formula, pro-

cess or non-patented technical knowledge or other similar intangible prop-

erty is used.

5. Where, owing to a special relationship between the payer and the

recipient of the royalties or between both of them and some other person,

the amount of the royalties paid having regard to the use, right or informa-

tion for which they are paid, exceeds the amount which would have been

agreed upon by the payer and the recipient in the absence of such rela-

tionship, the provisions of this Article shall apply only to the last-men-

tioned amount. In that case the excess part of the payment shall remain

taxable according to the laws of the Member State in which the royalty is

deemed to arise.

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Article 14

Management Fees

1. Management fees arising in a Member State and paid to a resident

of another Member State shall be taxed only in the first-mentioned State.

2. The rate of tax shall not exceed fifteen per cent of the management

fees.

3. In this Article, the term “management fees” means payments of any

kind to any person, for or in respect of the provision of industrial or

commercial advice or for management or technical services or similar

services or facilities, but does not include payments for professional

services mentioned in Article 16.

4. Management fees shall be deemed to arise in a Member State when

the payer is that Member State itself, a local authority or a resident of that

Member State.

5. Where owing to a special relationship between the payer and the

recipient of the management fees or between both of them and some other

person, the amount of the management fees paid, having regard to the ad-

vice or services for which they are paid, exceeds the amount which would

have been agreed upon by the payer and recipient in the absence of such

relationship, the provisions of this Article shall apply only to the last-men-

tioned amount. In that case the excess part of the payment shall remain

taxable according to the laws of the Member State in which the manage-

ment fees arise.

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Article 15

Dependent Personal Services

1. Subject to the provisions of Articles 17, 19, and 20, salaries, wages

and other similar remuneration derived by a resident of a Member State

in respect of an employment shall be taxed only in the Member State in

which the employment is exercised.

2. Notwithstanding the provisions of Paragraph 1 of this Article, re-

muneration derived by a resident of a Member State in respect of an

employment exercised in another Member State shall be taxed only in

the first-mentioned State if-

(a) the recipient is present in the other State for a period or

periods not exceeding an aggregate 183 days in the tax

year; and

(b) the remuneration is paid by, or on behalf of, an employer

who is not a resident of the other State; and

(c) such remuneration is not deducted in arriving at the profits

of a trade, business, profession or vocation which is car-

ried on by the employer in the other Member State.

3. Notwithstanding the preceding provisions of this Article, remuner-

ation derived in respect of an employment exercised aboard a ship or

aircraft operating in international traffic shall be taxed only in the Mem-

ber State in which the person operating the ship or aircraft is a resident.

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Article 16

Independent Personal Services

1. Income derived by an individual, who is a resident of a Member State

engaged in rendering professional services of an independent character,

shall be taxable only by the Member State wherein such services are ren-

dered.

2. Where a resident of a Member State derives income from another

Member State in respect of professional services or other independent

activities of a similar character, such person shall be subject to tax in that

other Member State but only in respect of such income as is attributable

to the services or activities performed in that other Member State. In

determining the income attributable to such services or activities there

shall be allowed as a deduction such expenses wherever incurred as

would be deductible in accordance with the laws of that other Member

State.

3. In this Article, the term “professional services” includes, but is not

restricted to, independent scientific, technical, literary, artistic, educational

and teaching activities as well as the independent activities of physicians,

lawyers, engineers, architects, dentists and accountants.

Article 17

Directors’ Fees

Directors’ fees and similar payments derived by a resident of a Member

State in his capacity as a member of the Board of Directors of a Company

which is a resident of another Member State shall be taxed only in that

Member State of which the payer is a resident.

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Article 18

Entertainers and Athletes

1. Notwithstanding anything contained in this Agreement, income de-

rived by entertainers, including theatre, motion picture, radio or television

artistes and musicians, and by athletes, from their personal activities as

such shall be taxed only in the Member State in which those activities are

performed.

2. Where income in respect of personal activities of any entertainer

or athlete as such accrues not to that entertainer or athlete himself but to

another person, that income shall, notwithstanding anything contained in

this Agreement, be taxed only in the Member State in which the activities

of the entertainer or athlete are performed.

3. The provisions of paragraphs 1 and 2 shall not apply to:

(a) income derived from activities performed in a Member

State by entertainers or athletes if the visit to that Mem-

ber State is substantially supported by public funds of the

other Member State, including any political subdivision,

local authority or statutory body thereof;

(b) a non-profit organisation no part of the income of which

was payable to, or was otherwise available for, the per-

sonal benefit of any proprietor, member or shareholder

thereof; or

(c) an entertainer or athlete in respect of services provided

to an organisation referred to in subparagraph (b).

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Article 19

Pensions and Annuities

1. Pensions, annuities, alimony and other periodic payment of a simi-

lar character paid by a resident of a Member State to an individual who is

a resident of another Member State shall be taxable only by the State where

the contract providing for such periodic payment is executed and, if there is

no contract, by the State from which the payment of such income is liable

to be made.

2. Any pensions paid by a Member State or local authority or under

any Social Security or National Insurance Scheme established under the

laws of a Member State shall be taxable only in that Member State.

3. In this Article, the word “pensions” means periodic payments made

after retirement or death in consideration for services rendered, or by way

of compensation for injuries received in connection with past employment.

4. In this Article, the word “annuities” means a stated sum paid peri-

odically at stated times during life or during a specified or ascertainable

period of time under an obligation to make payments in return for adequate

and full consideration in money or money’s worth.

5. In this Article, the word “alimony” means periodic payments

made pursuant to a decree of divorce or of separate maintenance or of

separation.

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Article 20

Government Service

1. (a) Remuneration other than pensions paid by a Member State

or local authority thereof to any individual in respect of

services rendered to that Member State or authority shall

be taxable only in that Member State.

(b) However, such remuneration shall be taxable only in an-

other Member State if the services are rendered in that

other State and the individual is a resident of that State

who -

(i) is a national of that State; or

(ii) did not become a resident of that State solely for

the purpose of rendering the services.

2. The provisions of this Article shall not apply to payments in re-

spect of services rendered in connection with any trade or business car-

ried on by a Member State or local authority thereof.

Article 21

Students and Trainees

1. An individual who is a resident of a Member Sate immediately

before his visit to another Member State and who is temporarily present

in that other Member State for the primary purpose of-

(i) studying in that other Member State at a University or other

educational institution approved by the appropriate educa-

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tional authority of that Member State;

(ii) securing training required to qualify him to practice a

profession or a professional specialty; or

(iii) studying or doing research as a recipient of a grant, allow-

ance, or award from a governmental, religious, charitable,

scientific, literary or educational organisation, or as a par-

ticipant in other sponsored programmes,

shall not be taxable in respect of-

(a) gifts from abroad for the purpose of his maintenance, edu-

cation, study, research or training;

(b) the grant, allowance or award; and

(c) remuneration for employment in that other Member State

provided that the remuneration constitutes earnings reason-

ably necessary for the maintenance and education of such

person.

2. The benefits under paragraph 1 shall only extend for such period of

time as may be reasonable or customarily required to effectuate the pur-

pose of the visit.

General Provisions

Article 22

Non-discrimination

1. The nationals of a Member State shall not be subjected in any other

Member State to any taxation or any requirement connected therewith which

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is other or more burdensome than the taxation and connected require-

ments to which the nationals of that other Member State in the same cir-

cumstances are or may be subjected.

2. The provisions of this Article shall not be construed as obliging a

Member State to grant to residents of another Member State those per-

sonal allowances, credits and reliefs for tax purposes which are by law

available only to residents of the first-mentioned Member State.

3. In this Article the term “taxation” means taxes which are the sub-

ject of this Agreement.

Article 23

Consultation

1. Where a person who is a resident of a Member State considers

that the actions of one or more of the Member States result or will result in

taxation not in accordance with this Agreement, such person may, notwith-

standing the remedies provided by the laws of those States, present a case

to the competent authority of the Member State of which he is a resident.

2. The competent authority shall endeavour, if the objection appears

to it to be justified and if it is not itself able to arrive at an appropriate

solution, to resolve that case by agreement with the competent authority

of the other Member State, with a view to the avoidance of taxation not in

accordance with this Agreement.

3. The competent authorities of the Member States shall endeavour

to resolve by agreement any difficulties or doubts arising as to the inter-

pretation or application of this Agreement. They may also consult to-

gether for the elimination of double taxation in cases not provided for in

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this Agreement.

4. The competent authorities of the Member States may communicate

directly with each other for the purpose of reaching an agreement in accor-

dance with the provisions of the preceding paragraphs.

Article 24

Exchange of Information

1. The competent authorities of the Member States shall exchange such

information as is necessary for the carrying out of this Agreement and of the

domestic laws of the Member States concerning taxes covered by this

Agreement in so far as the taxation thereunder is in accordance with this

Agreement. Any information so exchanged shall be treated as secret and

shall only be disclosed to persons or authorities including Courts and other

administrative bodies concerned with the assessment or collection of the

taxes which are the subject of this Agreement. Such persons or authorities

shall use the information only for such purposes and may disclose the infor-

mation in public court proceedings or judicial decisions.

2. In no case shall the provisions of paragraph 1 be construed so as to

impose on one of the Member States the obligation:

(a) to carry out administrative measures at variance with the

laws or the administrative practice of that or of the other

Member States;

(h) to supply particulars which are not obtainable under the laws

or in the normal course of the administration of that or of

the other Member States;

(c) to supply information which would disclose any trade, busi-

ness, industrial, commercial or professional secret or trade

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process the disclosure of which would be contrary to pub-

lic policy.

Article 25

Diplomats and Consular Officials

Nothing in this Agreement shall affect the fiscal privileges of members

of diplomatic missions or consular posts under the general rules of interna-

tional law or under the provisions of special agreements.

Article 26

Signature

This Agreement shall be open for signature by any Member State.

Article 27

Ratification

This Agreement and any amendments thereto shall be subject to ratifi-

cation by the Member States in accordance with their respective constitu-

tional procedures. Instruments of ratification shall be deposited with the

Caribbean Community Secretariat which shall transmit certified copies to

the Government of each Member State.

Article 28

Entry Into Force

1. This Agreement shall enter into force on the deposit of the

second instrument of ratification in accordance with Article 27 and shall

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thereupon take effect-

(a) in respect of taxes withheld at the source, on amounts paid

or credited to a person, on the first day of the calendar

month next following the month of deposit of the second

instrument of ratification;

(b) in respect of other taxes, for the taxable years beginning on

or after the first day of January next following the deposit of

the second instrument of ratification.

2. Where a State ratifies this Agreement after it has entered into force,

the Agreement shall take effect in relation to that State in respect of the

taxes mentioned in paragraph 1 (a), on the first day of the calendar month

next following the deposit of its instrument of ratification.

3. In such event this Agreement shall cease to have effect in relation

to that Member State-

(a) in respect of taxes withheld at source on amounts paid or

credited to a person, from the first day of January next fol-

lowing the year in which the notice of termination is given;

(b) in respect of other taxes, for the taxable years commenc-

ing on or after the first day of January next following the

year in which the notice of termination is given.

IN WITNESS WHEREOF the undersigned, duly authorized thereto,

have signed the present Agreement.

SIGNED by this 6th day of July, 1994 at Sherbourne

Conference Center, St. Michael, Barbados for the Government of Antigua

and Barbuda.

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SIGNED by Hon. Manuel Esquivel this 6th day of July, 1994 at

Sherbourne Conference Centre, St. Michael, Barbados for the Govern-

ment of Belize.

SIGNED by this day of 19 at

for the Government of Dominica.

SIGNED by this 6th day of July, 1994 at

Sherbourne Conference Centre, St. Michael, Barbados for the Govern-

ment of Grenada.

SIGNED by this day of 19 at for

the Government of Guyana.

SIGNED by this 6th day of July, 1994 at Sherbourne

Conference Centre, St. Michael, Barbados for the Government of Ja-

maica.

SIGNED by this day of 19 at for

the Government of Montserrat.

SIGNED by this 6th day of July, 1994 at Sherbourne

Conference Centre, St. Michael, Barbados for the Government of St.

Kitts and Nevis.

SIGNED by this 6th day of July, 1994 at Sherbourne

Conference Centre, St. Michael, Barbados for the Government of Saint

Lucia.

SIGNED by this 6th day of July, 1994 at

Sherbourne Conference Centre, St. Michael, Barbados for the Govern-

ment of St. Vincent and the Grenadines.

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SIGNED by this 6th day of July, 1994 at

Sherbourne Conference Centre, St. Michael, Barbados for the Govern-

ment of Trinidad and Tobago.

SCHEDULE II

TAXES COVERED

The Taxes which are the subject of this Agreement are:

(a) in Antigua and Barbuda

(i) Income Tax

(ii) Business Tax

(b) in Belize

- Income Tax

(c) in Dominica

- Income Tax

(d) in Grenada

- Income Tax

(e) in Guyana

(i) Income Tax

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(ii) Corporation Tax

(iii) Capital Gains Tax

(f) in Jamaica

(i) Income Tax

(ii) Transfer Tax in relation to Capital Gains

(g) in Montserrat

- Income Tax

(h) in St. Kitts and Nevis

- Income Tax

(i) in Saint Lucia

- Income Tax

(j) in St. Vincent and the Grenadines

- Income Tax

(k) in Trinidad and Tobago

(i) Income Tax

(ii) Corporation Tax

(iii) Unemployment Levy

(iv) Health Surcharge

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(v) Petroleum Profits Tax

(vi) Supplemental Petroleum Tax

(vii) Business Levy

SCHEDULE III

MEMBER STATES

Antigua and Barbuda Jamaica

Belize Montserrat

Dominica St. Kitts and Nevis

Grenada Saint Lucia

Guyana Trinidad and Tobago

St. Vincent and the Grenadines
Read Entire Law on www.belizelaw.org