The Caribbean region is renowned for its appealing tax structures, particularly beneficial for investors and entrepreneurs aiming to lower their tax obligations while relishing the allure of a tropical haven.

Nonetheless, not all Caribbean nations adhere to identical tax regulations and rates. Many have recently made noteworthy adjustments to align with international norms and to attract increased foreign investment. 

If you are considering obtaining a second citizenship through the Citizenship by Investment (CBI) program, you might be wondering how the tax systems of different CBI nations compare. In this blog post, we will provide a comprehensive comparison of the tax systems in Grenada, Dominica, St. Lucia, Antigua and Barbuda, and St. Kitts and Nevis. We will cover the following topics:

• Income Tax
• Corporate Tax
• Value-Added Tax (VAT)
• Excise Tax
• Property Tax
• Capital Gains Tax
• Payroll Tax
• Environmental Taxes
• Inheritance and Estate Tax
  

I. Personal Income Tax:

Personal income tax pertains to the earnings of individuals who are residents or have income sources within a Caribbean country. Residency criteria vary but typically revolve around physical presence, domicile, or permanent residence. Income sources are usually determined by where the income originates or is received.

Table 1 Personal income tax rates for 2023 

The income tax systems of Grenada, Dominica, St Lucia, Antigua and St Kitts are similar in many aspects, but they also have some differences in terms of the deductions and allowances that are available to individual taxpayers. The table below will compare and contrast these features for the income year 2023.

Table 2   Allowable Deductions and Allowances for FY 2023

In addition, Table 3 Special Features of each countries’ tax system:

Table 3 Special Features of each countries’ Personal Income Tax system

The table above shows the special features of each country’s personal income tax system, which are the aspects that make them different from other countries or from the common practice.

II. CORPORATE TAX

Antigua and Barbuda, Dominica, Grenada, St. Lucia, and St. Kitts and Nevis are all Caribbean nations that offer attractive tax regimes for businesses. These countries have different corporate tax systems and rates. The table below presents the corporate tax rates of country, followed by a discussion of exemptions, exclusions, and deductions allowed, shedding light on their unique approaches to fostering economic growth and investment.

Table 4 Corporate Tax Rates (2023)

Exemptions, Exclusions, and Deductions 

These countries provide various exemptions, exclusions, and deductions for businesses to reduce their corporate tax liability:

• Antigua and Barbuda: Businesses may benefit from exemptions on certain types of income, such as income from dividends received from another resident company. In addition, there are deductions available for expenses related to income generation, such as business expenses.
• Dominica: Businesses may benefit from exemptions on certain types of income, such as income from dividends received from another resident company. In addition, there are deductions available for expenses related to income generation, such as business expenses.
• Grenada: Businesses may benefit from exemptions on certain types of income, such as income from dividends received from another resident company. In addition, there are deductions available for expenses related to income generation, such as business expenses.
• St. Lucia: Businesses may benefit from exemptions on certain types of income, such as income from dividends received from another resident company. In addition, there are deductions available for expenses related to income generation, such as business expenses.
• St. Kitts and Nevis: Businesses may benefit from exemptions on certain types of income, such as income from dividends received from another resident company. In addition, there are deductions available for expenses related to income generation, such as business expenses.

III. VAT

Value Added Tax (VAT) serves as a cornerstone of revenue generation for many countries, providing vital funding for public services and development. VAT rates, thresholds, exemptions, and exclusions vary across different countries and regions. The table below provides details on the VAT rates and systems of Antigua and Barbuda, Dominica, Grenada, St. Lucia, and St. Kitts and Nevis for the year 2023. Beyond just VAT rates, you can also see a snapshot of allowable exemptions, and various features of their VAT systems that are crucial for businesses, consumers, and policymakers.

Table 5 VAT RATES, Exemptions and Features in 2023

As we can see from the table above, St Kitts and Nevis has the highest standard VAT rate of 17%, while St Lucia has the lowest rate of 12.5%.

VAT Thresholds

The threshold for VAT registration is the minimum annual turnover that a business must have before it is required to register for VAT. The table below shows the VAT registration thresholds for the five Caribbean countries:

Table 6 VAT thresholds

As we can see from the table above, St Lucia has the highest VAT registration threshold of 400,000 XCD per annum,  while St. Kitts and Nevis has the lowest threshold of 150,000 XCD per annum.

IV. EXCISE TAX

The world of taxation is a tapestry woven with diverse threads, and excise tax is one such intricate strand that intricately impacts specific goods and services. Tobacco, alcohol, sugar-sweetened beverages, and fossil fuels are among the focal points of this indirect taxation approach. Excise taxes serve a multitude of purposes, from revenue generation to addressing externalities and discouraging the consumption of potentially harmful products. Let us embark on a journey to dissect and compare the excise tax systems of five Caribbean nations: Antigua and Barbuda, Dominica, St. Lucia, St. Kitts and Nevis, and Grenada. We’ll delve into the latest data available in 2023, illuminating the unique features that distinguish each nation’s fiscal strategy.

Antigua and Barbuda:

Antigua and Barbuda’s excise tax framework covers alcoholic beverages, tobacco products, petroleum products, and motor vehicles. The rates are not uniform and depend on the product type and quantity. For example, beer is taxed at 60% of the cost price, while cigarettes face an excise tax of EC$6 per pack of 20. Motor vehicle rates range from 15% to 70%, contingent on engine size and vehicle age.

Dominica:

Dominica’s excise tax landscape includes alcoholic beverages, tobacco products, petroleum products, motor vehicles, and environmental charges. Rates are influenced by product specifics. For instance, beer is subject to an excise tax of EC$2.50 per liter, while cigarettes face a tax of EC$5 per pack of 20. Motor vehicle taxes span from 28% to 120%, based on engine size and age. Environmental levies extend to items like plastic bags, disposable containers, tires, batteries, and electronic waste.

St. Lucia:

St. Lucia’s excise tax system encompasses alcoholic beverages, tobacco products, petroleum products, motor vehicles, and environmental surcharges. Rates are tailored to each product category. For example, beer carries an excise tax of EC$2.50 per liter, while cigarettes bear a tax of EC$4 per pack of 20. Motor vehicle rates range from 10% to 140%, mirroring engine size and vehicle age. Environmental surcharges apply to plastic bags, disposable containers, tires, batteries, and electronic waste.

St. Kitts and Nevis:

St. Kitts and Nevis employs excise taxes on alcoholic beverages, tobacco products, petroleum products, motor vehicles, sugar-sweetened beverages, and environmental levies. Rates flex based on the nature of the product. For instance, beer is assigned an excise tax of EC$2 per liter, while cigarettes face an excise tax of EC$5 per pack of 20. Motor vehicle rates span 5% to 145%, contingent on engine size and vehicle age. Sugar-sweetened beverages encounter an excise tax equivalent to 10% of the cost price. Environmental levies cover items like plastic bags, tires, and electronic waste.

Grenada:

Grenada’s excise tax system spans a broad array of products, including alcoholic beverages, tobacco products, petroleum products, motor vehicles, and a range of food and beverage items. Rates vary based on product specifics. For instance, beer faces an excise tax of EC$2.50 per liter, while cigarettes are taxed at EC$5 per pack of 20. Motor vehicle taxes span from 5% to 150%. Environmental levies encompass items like plastic bags, tires, and electronic waste.

Comparative Insight:

This highlights the shared focus on excise taxes across the five Caribbean countries, while also revealing variations in rates and product categories. Grenada’s expansive list reflects its commitment to health concerns and recovery efforts, while other nations may prioritize different fiscal objectives. The excise tax systems of these nations underscore the unique strategies each adopts to navigate their financial and societal landscapes.

V. PROPERTY TAX

Property tax is a levy imposed by the government on the value of real estate or immovable property. It is one of the main sources of revenue for many countries, especially in the Caribbean region. However, property tax rates and rules vary significantly among different Caribbean countries, depending on their economic, social and political factors. In this blog post, we will compare the 2023 property tax system in five Caribbean countries: Grenada, Dominica, St Lucia, Antigua and Barbuda, and St Kitts and Nevis. We will cover the following aspects:

• Property tax rates
• Property tax base and valuation
• Property tax exemptions and exclusions
• Special features of property tax system

Property Tax Rates

The property tax rate is the percentage of the property value that is charged as tax. It can be a flat rate or a progressive rate that increases with the value of the property. The table below shows the property tax rates for residential and commercial properties in the five Caribbean countries.

Table 6 Property Tax rates

Please note that these are just general rates and may vary depending on the specific circumstances. For example, there may be additional deductions or exemptions available for certain categories of properties, such as hotels or apartment buildings. It is always best to consult with a tax advisor to get the most accurate information. 

Property Tax Base and Valuation

The property tax base is the value of the property that is subject to taxation. It can be based on the market value, the rental value, the cost of construction or a combination of these methods. The property tax valuation is the process of determining the property tax base using various techniques and data sources.

In Grenada, Dominica, St Lucia and Antigua and Barbuda, the property tax base is based on the market value of the property, which is the price that a willing buyer would pay to a willing seller in an open market. The market value is determined by professional valuers using sales comparison, income capitalization or cost approaches.

In St Kitts and Nevis, the property tax base is based on the rental value of the property, which is the amount of rent that a tenant would pay to a landlord for occupying the property. The rental value is determined by professional valuers using market data and analysis.

Property Tax Exemptions and Exclusions

Property tax exemptions and exclusions are provisions that reduce or eliminate the property tax liability for certain types of properties or owners. They are usually granted for social, economic or environmental reasons.

In Grenada, Dominica, St Lucia and Antigua and Barbuda, there are various property tax exemptions and exclusions available for:

• Government-owned properties
• Religious properties
• Educational properties
• Charitable properties
• Agricultural properties
• Historical or cultural properties
• Properties below a certain threshold value

In St Kitts and Nevis, there are no property tax exemptions or exclusions available for any type of properties or owners.

Special Features of Property Tax System

Some Caribbean countries have special features in their property tax system that make them more attractive or unique for investors or residents.

In Grenada, there are no taxes on inheritance or capital gains, which means that property owners do not have to pay any taxes when they transfer or sell their properties.

VI. CAPITAL GAINS TAX

Capital gains tax (CGT) is a tax imposed on the profit or gain from the sale or transfer of an asset, such as land, property, shares, or securities. Different countries have varying rules and rates for CGT, and some do not impose it at all. In this blog post, we will compare the CGT regimes of five Caribbean countries: Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, and St. Lucia. We will focus on the CGT rates and rules for both residents and non-residents as of 2023.

According to latest data, none of these five countries have a specific CGT regime for corporations or individuals. This means that capital gains are either exempt from tax or subject to the normal income tax rates.

There is no CGT on the sale of immovable property in Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, and St. Lucia. However, there may be other taxes or fees involved in the transfer of property, such as stamp duty, land transfer tax, registration fee, or legal fee. These taxes or fees vary by country and may depend on the value or location of the property.

Another example is the taxation of dividends from shares or securities. Dividends paid by resident companies to resident shareholders are subject to a withholding tax of 10% in Antigua and Barbuda, 15% in Dominica, 10% in Grenada, and 15% in St. Lucia. However, dividends paid by resident companies to non-resident shareholders are subject to a higher withholding tax of 25% in Antigua and Barbuda, 25% in Dominica, 15% in Grenada, and 25% in St. Lucia. In contrast, dividends paid by non-resident companies to resident or non-resident shareholders are generally exempt from tax in these countries. St. Kitts and Nevis imposes a withholding tax of 15% on dividends paid by resident entities to non-residents.

Here’s a table that summarizes the taxation of dividends from shares or securities in the five Caribbean countries mentioned in the text:

Table 7. Withholding tax on Dividends

As you can see, the withholding tax rate on dividends paid by resident companies to resident shareholders is 0% in Antigua and Barbuda and St. Kitts and Nevis. This means that no tax is withheld on dividends paid to resident shareholders of these companies. However, a 15% withholding tax is applied to dividends paid by resident companies to non-resident shareholders in all five countries.

In the case of non-resident companies, the tax treatment is more complicated. In some cases, there may be no tax withheld on dividends paid to resident or non-resident shareholders. However, in other cases, a withholding tax may be applied. The exact rate will depend on the specific circumstances and the tax treaties between the countries involved.

VII. PAYROLL TAX

Payroll tax is a type of tax that employers and employees pay on wages and salaries. It can include income tax, social security contributions, and other levies depending on the country. Table 8 compares the rates of social security contribution in Antigua and Barbuda with four other Caribbean countries: Grenada, Dominica, St. Lucia, and St. Kitts and Nevis.

Table 8 Social Security Contribution

While there is no income tax in Antigua and Barbuda, In the 2023 budget statement delivered on February 17th, several amendments to the Payroll Tax were introduced, effective from April 1, 2023. The changes are as follows:

Table 9 changes to Antigua and Barbuda Payroll Tax

As we can see, there are significant differences in the payroll tax system among these Caribbean countries. Antigua and Barbuda has the highest income tax rates, but also the highest thresholds. Grenada has the lowest income tax rate, but also the lowest threshold. Dominica has the highest social security contribution rate, while St. Kitts and Nevis has none. These factors may affect the attractiveness of these countries for businesses and workers.

VIII. Environmental Taxes in the Caribbean

Environmental taxes are an important policy tool for addressing the challenges of climate change, biodiversity loss, ocean pollution and water scarcity. They can help to reduce greenhouse gas emissions, promote the transition to renewable energy, encourage resource efficiency and generate revenues for environmental protection and social development. In this article, we will compare the environmental taxes system in 2023 of five small island states in the Caribbean: Antigua and Barbuda, Dominica Grenada, St. Lucia and St. Kitt and Nevis.

The environmental taxes in Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, and St. Lucia are all designed to raise revenue to fund environmental protection and conservation programs. The specific taxes and rates vary from country to country, but they all have the same goal of reducing pollution and protecting the environment.

The environmental taxes in these countries are a relatively new phenomenon, and they are still evolving. However, they have the potential to play a significant role in financing environmental protection and conservation efforts in the Caribbean region.

Here is a comparison of the environmental taxes in the five countries:

Table 10 Environmental Rates and their purposes

Comparison and Conclusion

The table below summarizes the main features and outcomes of the environmental taxes system in 2023 of Antigua and Barbuda, Dominica Grenada, St. Lucia and St. Kitts and Nevis.

Table 11 Main features and outcomes of the environmental taxes system

Source: World Bank annual report on environmental taxes and charges 2022 (pub 2023)

IX. INHERITANCE AND ESTATE TAX RATES

Inheritance and estate taxes are subjects of great concern for individuals planning their financial legacies. These taxes are levied on the transfer of assets to heirs or beneficiaries upon the death of the owner. Thus, these taxes can significantly impact the assets passed on to heirs and beneficiaries.   The Caribbean is a popular destination for wealthy individuals and families looking to avoid inheritance and estate taxes. There are no inheritance or estate taxes in Antigua and Barbuda, Dominica, Grenada, St. Lucia, and St. Kitts and Nevis.

This makes these countries attractive for individuals and families who want to pass on their assets to their heirs without having to pay a significant amount of tax. However, it is important to note that there may be other taxes that apply to the transfer of assets, such as stamp duty and Capital gains tax, etc.

Table 12 Inheritance and Estate Tax Rates, Stamp Duties, and Gift Taxes in the Caribbean in 2023

By the end of this post, you will have a better understanding of the tax implications of becoming a citizen of one of these CBI nations. However, please note that this post is for informational purposes only and does not constitute professional tax advice. Therefore, it is essential to seek professional advice from a qualified tax expert before engaging in any CBI schemes.  A tax professional can help you assess your tax obligations, plan your tax strategy, and avoid any potential pitfalls or risks associated with these schemes.

We hope that this blog article has provided you with some useful information and insights on the tax systems in CBI nations. If you have any questions or comments, please feel free to contact us.

Thank you for reading!