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Grenada Cross-Border Tax Guide: WHT, CARICOM DTTs, Transfer Pricing 2026

Grenada's cross-border tax framework features withholding taxes on outbound payments (dividends 15%, interest 15%, royalties 25%), a network of double taxation treaties under CARICOM, and transfer pricing rules. Here is how cross-border taxation works in 2026.

Cross-border taxation in Grenada is governed by domestic tax law and Grenada's double taxation treaties under the CARICOM Double Taxation Agreement. The system facilitates international trade and investment within the Caribbean region while protecting Grenada's tax base. Withholding tax rates apply to certain payments from Grenadian residents to non-residents. Transfer pricing rules ensure that transactions between related parties are conducted at arm's length. The Inland Revenue Division has a dedicated international tax unit. Investment income tax →

Real-world example: A US company receives XCD 100,000 in dividends from its Grenadian subsidiary. WHT at 15% = XCD 15,000, net payment = XCD 85,000. A Canadian company receives XCD 50,000 in royalties from a Grenadian licensee: WHT at 25% = XCD 12,500. Under the CARICOM DTA with Barbados, dividends may benefit from reduced rates. Grenada has no exchange controls, so funds can be freely repatriated. Corporate tax overview →

Withholding Tax Rates

  • Dividends to non-residents: 15% (may be reduced under DTT)
  • Interest to non-residents: 15% (may be reduced under DTT)
  • Royalties to non-residents: 25% (may be reduced under DTT)
  • Dividends to residents: 0%
  • Interest to residents: 0%

WHT applies to payments made by Grenadian residents to non-residents. The payer is responsible for withholding and remitting the tax to the IRD. Treaty relief requires the recipient to provide a Certificate of Tax Residency and beneficial ownership declaration.

Double Taxation Treaties

Grenada's DTT network is primarily through the CARICOM Double Taxation Agreement. Treaties generally provide for:

  • Dividends: Reduced rates typically 5-15% (compared to 15% domestic)
  • Interest: Reduced rates typically 10-15% (compared to 15% domestic)
  • Royalties: Reduced rates typically 10-15% (compared to 25% domestic)
  • Business profits: Only taxable in the source country if there is a permanent establishment
  • Capital gains: Generally taxable in the country of residence of the seller
  • Employment income: Taxable in the work country (subject to the 183-day exemption for short assignments)

Key treaty partners under CARICOM: Barbados, Trinidad & Tobago, Jamaica, Guyana, Belize, St. Lucia, St. Vincent & the Grenadines, Antigua & Barbuda, Dominica, St. Kitts & Nevis. Grenada also has bilateral treaties with a limited number of non-CARICOM countries.

Transfer Pricing

Grenada's transfer pricing rules follow international standards. Key requirements include:

  • Arm's length principle: Transactions between related parties must be conducted as if between independent entities
  • Documentation: Taxpayers should maintain transfer pricing documentation for significant related-party transactions
  • Methods: Acceptable methods include comparable uncontrolled price (CUP), cost plus, resale price, and transactional net margin method (TNMM)

Related parties include parent-subsidiary relationships, sister companies under common control, and individuals with significant influence over a company.

Permanent Establishment Risk

Non-resident companies may create a taxable presence (permanent establishment) in Grenada 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 28% on profits attributable to the PE.

Can I repatriate profits from Grenada tax-free?

Dividends paid to non-resident shareholders attract 15% WHT (subject to treaty reduction). Interest and royalties paid to non-residents attract 15% and 25% WHT respectively. There is no exchange control restriction on repatriation of funds.

What is the procedure for claiming DTT benefits?

The non-resident must provide the Grenadian payer with: a completed Treaty Relief Application form, a Certificate of Tax Residency from the home country tax authority, and a declaration of beneficial ownership. The payer then applies the treaty rate at source.