Barbados is ahead of the curve with regards to the adoption of the Organisation of Economic Cooperation and Development’s Pillar 2 of the Base Erosion and Project Shifting Initiative.
Recently announcing a suite of changes to the country’s corporate tax regime, Prime Minister the Hon. Mia Amor Mottley, S.C., M.P., has assured that reforms to Barbados’ tax structure will be implemented in 2024.
Among these changes will include, effective January 1, 2024, an increased corporate tax rate to 9% for all corporations, with some exceptions. The 9% corporate tax rate will not apply to the following classes of entities:
- Businesses with revenue at or below Bds$2 million which are registered under the Small Business Development Act Cap318C. These entities will be subject to corporation tax at the rate of 5.5%.
- Insurance entities – These entities will continue to be subject to tax at the current rates of 0% for Class 1 Licensees and 2% for Class 2 and 3 Licensees.
- Shipping entities – These entities are out of scope of Pillar Two rules and will continue to be subject to the existing regime of 5.5% – 1% depending on their level of income. Further evaluation will occur to determine whether change will be required for fiscal year 2025 and after.
Additionally, with effect from January 1, 2024, a Qualified Domestic Minimum Top-Up Tax (QDMTT) will be implemented. The QDMTT will top-up the Barbados effective corporation tax payable by an in-scope multinational enterprise to 15%. The top-up tax will not apply to in-scope multinational enterprises where the Ultimate Parent Entity is in a jurisdiction which has not implemented an Income Inclusion Rule (IIR) or where the Constituent Entities are not subject to an IIR or an Undertaxed Profits Rule.
The Barbados Revenue Authority will be responsible for the administration of the QDMTT.