A Protocol amending the Canada-Barbados income tax treaty entered into force on December 17, 2013. This treaty was signed the protocol on November 2011. The Protocol, following OECD style exchange of information language, includes some significant changes to the tax treaty, including measures that:
- Introduce a “look-through” rule for gains derived from dispositions of shares and partnership, trust and other interests that derive their value principally from immovable property stays in a treaty-partner country;
- Allow Barbados international business companies (IBC), exempt insurance companies, qualifying insurance companies and similar entities to be considered residents of Barbados under Article IV (but still not entitled to treaty benefits under Articles VI to XXIV); and
- Change tie-breaker rules for the residents.
