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

Q: Can I repatriate profits from Guyana tax-free?

Dividends to non-residents: 20% WHT (treaty-reducible). Interest: 15% WHT (treaty-reducible). Royalties: 10% WHT (treaty-reducible). No branch remittance tax.

Q: What is the procedure for claiming DTT benefits?

Provide the payer with a Treaty Relief Application, Certificate of Tax Residency, and beneficial ownership declaration. Apply treaty rate at source or claim a refund.

Guyana's cross-border tax framework features withholding taxes on outbound payments (dividends 20%, interest 15%, royalties 10%), a limited network of Double Taxation Treaties (CARICOM, UK, Canada), and transfer pricing rules. Here is how cross-border taxation works in 2026.

Cross-border taxation in Guyana is governed by domestic tax law and Guyana's Double Taxation Treaties. Withholding tax rates apply to certain payments from Guyanese residents to non-residents. Transfer pricing rules ensure that transactions between related parties are conducted at arm's length. The GRA has a dedicated international tax unit for cross-border matters. Guyana has no exchange controls. Investment income tax →

Real-world example: A Canadian company receives GYD 10,000,000 in dividends from its Guyanese subsidiary. Without a treaty, WHT at 20% = GYD 2,000,000. Under the Guyana-Canada DTT, the rate may be reduced to 15% = GYD 1,500,000. A US company licensing software to a Guyanese company receives GYD 5,000,000 in royalties: domestic WHT 10% = GYD 500,000. As the US does not have a DTT with Guyana, the full 10% applies. Corporate tax overview →

Withholding Tax Rates

Dividends to non-residents: 20% (may be reduced under DTT)
Interest to non-residents: 15% (may be reduced under DTT)
Royalties to non-residents: 10% (may be reduced under DTT)

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

Double Taxation Treaties

Guyana has a limited DTT network. Treaties generally provide for:

Dividends: Reduced rates typically 10-15% (compared to 20% domestic)
Interest: Reduced rates typically 10-12% (compared to 15% domestic)
Royalties: Reduced rates typically 5-10% (compared to 10% domestic)
Business profits: Only taxable in the source country if there is a permanent establishment
Employment income: Taxable in the work country (subject to the 183-day exemption for short assignments)

Key treaty partners: CARICOM member states (Trinidad and Tobago, Jamaica, Barbados, etc.), UK, Canada. Guyana is actively expanding its treaty network, particularly with major trading partners in light of oil and gas sector growth.

Permanent Establishment Risk

Non-resident companies may create a taxable presence (permanent establishment) in Guyana 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 in any 12-month period. A PE is subject to CIT at 25% on profits attributable to the PE.

Can I repatriate profits from Guyana tax-free?

Dividends paid to non-resident shareholders attract 20% WHT (subject to treaty reduction). Interest and royalties paid to non-residents attract 15% and 10% WHT respectively. 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 Guyanese 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. Alternatively, tax can be withheld at the domestic rate and the non-resident can file a refund claim.