• Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 12/24/2013

Canada - Protocol with Barbados enters into force 

December 24: A Protocol amending the Canada-Barbados income tax treaty entered into force 17 December 2013.

Canada and Barbados signed the Protocol in November 2011. The Protocol, in addition to the inclusion of OECD-style exchange of information language, includes several significant changes to the treaty, including measures that:

  • Introduce a “look-through” rule for gains derived from dispositions of shares and partnership, trust and other interests that derive their value principally from immovable property situated in a treaty-partner country
  • Allow Barbados international business companies (IBC), exempt insurance companies, qualifying insurance companies and similar entities to be considered residents of Barbados under Article IV (but still not entitled to treaty benefits under Articles VI to XXIV)
  • Change the resident tie-breaker rules

Read a December 2013 report prepared by the KPMG member firm in Canada: Canada-Barbados Protocol Now Enters Into Force

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