Topics of Interest |

Topics of Interest

Transfer Pricing in Caribbean Tax Law
DEFINITION Transfer pricing is the setting of the price for goods and services sold between controlled (or related) legal entities within an enterprise. THE "ARM'S LENGTH" PRINCIPLE In principle, a appropriate price is one that should match either what the seller would charge an independent (uncontrolled), arm's length customer, or what… Read More →
Special Tax Regimes (Registered Users Only)
In order to attract foreign direct investment, many Caricom countries have established special tax regimes. This note explores some of the special tax regimes that exist. Read More →
Caricom and OECD Treaties Compared (Registered Users only)
The OECD and UN Model Treaties have been analysed. Lots has been written. Too much infact. On the other hand, there is a dearth of commentary about the Caricom Double Tax Treaty. Jurists have often attempted to analyse the Caricom Treaty as if it is intended to operate like the OECD model, but… Read More →
Common Law Tradition
The region’s laws have evolved to meet the region’s very particular needs and have created a distinctive legal landscape. Within the so-called “developed” world, the evolution of tax law lies almost exclusively in the hands of the legislative drafter. These laws are subject to relatively frequent amendments in an effort to… Read More →
Branch or Subsidiary (Registered Users Only)
Branch or Subsidiary? A question frequently asked by multinational companies seeking to do business in the Caribbean is whether they should operate through a “branch” or, alternatively, whether they should operate via a locally incorporated “subsidiary company”. Regrettably, and all too often, the advice provided is couched in the following terms:… Read More →
Management Charges
DEFINITION In general/lay terms, a management charge/fee is a payment made by a company in one jurisdiction to a company in another jurisdiction for the provision of certain management services provided to it by the other. THE MULTI-NATIONAL BUSINESS CONTEXT In the specific context of developing countries, it is not… Read More →
Reverse Charges (VAT)
The underlying principle which governs the reverse charge mechanism is that it seeks to shift the liability to account for the VAT on specified imported services from the supplier to the customer. The general purpose is to reduce the administrative burden for the supplier to register for VAT in a… Read More →
Dispute Resolution Process
Abstract: This article deals with issues such as the procedural overview of a matter from assessment to appeal and includes issues such as the burden of proof in tax litigation matters. Read More →

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