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www.pwc.com/taxsummaries Worldwide Tax Summaries Corporate Taxes 2017/18 Quick access to information about corporate tax systems in 157 countries worldwide. Central America and the Caribbean Worldwide Tax Summaries Corporate Taxes 2017/18 All information in this book, unless otherwise stated, is up to date as of 1 June 2017. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors. © 2017 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details. Foreword Welcome to the 2017/18 edition of Worldwide Tax Summaries – Corporate Taxes, one of the most comprehensive tax guides available. This year’s edition provides detailed information on corporate tax rates and rules in 157 countries worldwide. As governments across the globe are Some of the enhanced features available looking for greater transparency and online include Quick Charts to compare with the increase of cross-border rates across jurisdictions. You may also activities, tax professionals often need access WWTS content through Tax access to the current tax rates and other Analysts at www.taxnotes.com. major tax law features in a wide range of countries. The country summaries, If you have any questions, or need more written by our local PwC tax specialists, detailed advice on any aspect of tax, include recent changes in tax legislation please get in touch with us. The PwC tax as well as key information about income network has member firms throughout taxes, residency, income determination, the world, and our specialist networks deductions, group taxation, credits and can provide both domestic and cross- incentives, withholding taxes, indirect border perspectives on today’s critical taxes, and tax administration. All tax challenges. information in this book, unless otherwise stated, is up to date as of 1 June 2017. Our online version of the summaries is available at www.pwc.com/taxsummaries. The Worldwide Tax Summaries (WWTS) website also covers the taxation of individuals and is fully mobile compatible, Colm Kelly giving you quick and easy access to Global Tax & regularly updated information anytime on Legal Services Leader your mobile device. PwC Ireland www.pwc.com/taxsummaries Foreword 1 Contents Foreword ...............................................1 Country chapters Antigua and Barbuda .............................4 Aruba ..................................................17 Barbados .............................................37 Bermuda .............................................55 Caribbean Netherlands ........................62 Cayman Islands ...................................68 Costa Rica ...........................................72 Curaçao ...............................................84 Dominica, Commonwealth of ............100 Dominican Republic ..........................108 El Salvador ........................................ 118 Guatemala .........................................131 Honduras ..........................................142 Jamaica .............................................154 Mexico ..............................................172 Nicaragua ..........................................205 Panama ............................................. 214 Puerto Rico........................................226 Saint Kitts and Nevis ..........................243 Saint Lucia ........................................256 Sint Maarten .....................................267 Trinidad and Tobago .........................280 Worldwide Tax Summaries Editorial Team ...................................292 2 Contents PwC Worldwide Tax Summaries Country chapters Central America and the Caribbean Antigua and Barbuda PwC contact Gloria Eduardo PricewaterhouseCoopers SRL The Financial Services Centre Bishop’s Court Hill PO Box 111 St. Michael, BB14004 Barbados, West Indies Tel: +1 246 626 6756 Email: [email protected] Significant developments Residential land and buildings used in commercial activities, such as short-term rental accommodation (less than 45 days), are now classified as other property and will be required to pay property tax as follows: • Residential buildings classified as other property: 0.50%. • Residential land classified as other property: 0.40%. Taxes on corporate income Companies incorporated in Antigua and Barbuda pay corporate income tax (CIT) on their worldwide income, with relief available under existing double taxation agreements (DTAs). Non-resident companies deriving income from Antigua and Barbuda are liable for CIT and should be registered if they have a physical presence in Antigua and Barbuda. Antigua and Barbuda imposes a flat CIT rate of 25%. Taxable income or chargeable income is ascertained by deducting from income all expenses that are wholly and exclusively incurred during the year for the production of that income. Chargeable income is normally arrived at by adjusting the net profit per the financial statements for non-taxable income, non-deductible expenses, and prior period losses of up to 50% of chargeable income. Where a person resident in Antigua and Barbuda makes to another person not resident in Antigua and Barbuda a payment other than interest, that person shall deduct or withhold 25% of that amount. Reduced CIT rate for certain financial institutions Financial institutions licensed under the Banking Act that maintain, throughout the tax year, residential mortgage rates at or below 7% are subject to a reduced CIT rate of 22.5%. Corporate residence A corporation is deemed to be a resident if it is incorporated in Antigua and Barbuda, if it is registered as an external company doing business in Antigua and Barbuda, or if the central management and control of its business are exercised in Antigua and Barbuda. www.pwc.com/taxsummaries Antigua and Barbuda 4 Antigua and Barbuda Permanent establishment (PE) The concept of a PE is described within a number of Antigua and Barbuda’s DTAs. A PE is, in general, created in line with the Organisation for Economic Co-operation and Development (OECD) Model Convention. A PE is not defined in the Income Tax Act; however, any company that would meet the general definition of a PE must be registered. Other taxes Antigua and Barbuda Sales Tax (ABST) ABST is an indirect tax and is levied at the rate of 15% on the value of a wide range of goods and services imported or supplied in Antigua and Barbuda by ABST-registered persons. The rate applied in respect of hotel accommodation is 12.5%. A number of services, including financial services, local transport, the sale of residential land, education, long-term accommodation (greater than 45 days), and medical and veterinary services, are exempt. Inter-group transactions are taxable. Persons operating under the ABST regime must be registered for ABST. The threshold for ABST registration is 300,000 East Caribbean dollars (XCD) in taxable activity per 12-month period. A period in the ABST Act represents one month. Certain supplies are zero-rated, including exports, basic food items, water, electricity for residential use, sale of new residential property, construction of new residential premises, and fuel. Registered persons may deduct input tax from their output tax in calculating the tax payable for that ABST accounting period. Where input tax exceeds output tax, the registrant will be entitled to a refund of ABST. Customs duties All imports are subject to customs duties, ABST, Revenue Recovery Charge (RRC), and environmental levy. In all instances, certain exemptions will apply. Customs duty is levied on a wide range of imported goods at rates from 0% to 70% as specified in the Custom Duties Act. Customs duty is levied on goods based on the cost, insurance, and freight (CIF) values and rates determined by the Caribbean Community (CARICOM) Common External Tariff. Antigua and Barbuda Revenue Recovery Charge (RRC) The Antigua and Barbuda RRC is applied at a flat rate of 10% on the CIF value on all goods imported into or produced in Antigua and Barbuda. Exemptions will include entities with which the government has International Assistance Agreements, certain government entities, and most supplies or imports of fuel. Excise taxes There are no excise taxes in Antigua and Barbuda. 5 Antigua and Barbuda PwC Worldwide Tax Summaries Antigua and Barbuda Property taxes Property tax is levied annually at graduated rates on the basis of the market value of real property (as assessed by the Property Valuation Department) and its use (residential or commercial). Property tax rates are as follows: • Agricultural land: 0.10%. • Residential land: 0.20%. • Residential building: 0.30%. • Buildings classified as other property: 0.50%. • Land classified as other property: 0.40%. Allowances and tax rebates are available as follows: • Dwelling house allowance of XCD 150,000 from the taxable value. • 5% rebate for payment of tax on or before the due date. • New dwelling house will be exempt from tax for the first two years of being habitable. • Between 25% and 100% tax rebate available for special development property and property for public use; 25% for hotels. Non-citizens undeveloped land tax Undeveloped land tax is levied on the basis of the value of land owned by non-citizens that has not been developed. The tax takes effect from the date of declaration by the government. Rates of tax are as follows: • First year of ownership: 10%. • Second
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