Antigua & Barbuda Cross-Border Tax Guide: 0% WHT, CARICOM DTTs 2026
Antigua and Barbuda applies a 0% withholding tax rate on dividends, interest, and royalties paid to non-residents. The country has a limited Double Taxation Treaty network primarily through the CARICOM agreement. The territorial system means foreign-source income is not taxed. Here is how cross-border taxation works in 2026.
Cross-border taxation in Antigua and Barbuda is governed by the Income Tax Act and is highly favorable for international investors. The absence of withholding taxes on outbound payments (dividends, interest, royalties) makes Antigua an attractive jurisdiction for holding companies and intellectual property. The territorial system further enhances Antigua's appeal by exempting foreign-source income from local tax. The Inland Revenue Department (IRD) handles cross-border tax matters. Investment income tax →
Real-world example: A US company receives XCD 500,000 in dividends from its Antiguan subsidiary. WHT: 0% = XCD 0. The full XCD 500,000 is remitted without deduction. An Italian company licensing software to an Antiguan company receives XCD 300,000 in royalties: WHT 0% = XCD 0. A UK lender receives XCD 200,000 in interest from an Antiguan borrower: WHT 0% = XCD 0. Compare this to jurisdictions with standard 15-30% WHT rates. Corporate tax overview →
Withholding Tax Rates
- Dividends to non-residents: 0% — no withholding tax on dividend payments
- Interest to non-residents: 0% — no withholding tax on interest payments
- Royalties to non-residents: 0% — no withholding tax on royalty payments
- Dividends to residents: 0%
- Interest to residents: 0%
Antigua and Barbuda does not impose withholding taxes on most outbound payments. This is a significant advantage for international business structures and makes Antigua a tax-efficient jurisdiction for cross-border payments.
Double Taxation Treaties
Antigua and Barbuda's DTT network is primarily through the CARICOM Double Taxation Agreement. Key points:
- CARICOM Agreement: Applies between CARICOM member states, providing for reduced withholding rates and elimination of double taxation
- CARICOM members: Trinidad and Tobago, Barbados, Jamaica, Guyana, Belize, St. Lucia, St. Vincent, Grenada, Dominica, and others
- Limited bilateral treaties: Antigua has few bilateral DTTs outside CARICOM
The limited treaty network is mitigated by the 0% domestic WHT rates and territorial system — there is little withholding tax to reduce through treaties.
Transfer Pricing
Antigua and Barbuda has transfer pricing rules aligned with OECD guidelines. Key requirements include:
- Arm's length principle: Transactions between related parties must be conducted at arm's length
- Documentation: Taxpayers must maintain transfer pricing documentation
- Methods: Acceptable methods include CUP, cost plus, resale price, TNMM, and profit split
The IRD may challenge transfer pricing arrangements that shift profits out of Antigua.
Permanent Establishment Risk
Non-resident companies may create a taxable presence in Antigua through: a fixed place of business (office, branch, workshop, construction site exceeding 6 months), a dependent agent with authority to conclude contracts, or provision of services through employees for more than 183 days. A PE is subject to CIT at 25% on profits attributable to the PE.
Can I repatriate profits from Antigua tax-free?
Yes. Dividends paid to non-resident shareholders attract 0% WHT. Interest and royalties to non-residents also attract 0% WHT. There is no branch remittance tax on profits remitted by a PE to its foreign head office.
What is the procedure for claiming DTT benefits?
The non-resident must provide the Antiguan payer with a Certificate of Tax Residency from their home country tax authority and a declaration of beneficial ownership. Given the 0% domestic WHT rates, treaty relief is generally not needed for most payments.