Does the abolition of personal income tax in Antigua and Barbuda make tax treaties irrelevant?

Not entirely. Antigua abolished personal income tax in 2016, so residents have no local income levy for a foreign credit to offset. However, corporate income tax remains at 25%, and non-residents face 25% withholding on Antiguan-source dividends, interest, and royalties. Treaties matter for those corporate and withholding-tax dimensions, reducing WHT rates for qualifying residents of CARICOM states, the UK, and the UAE.

What withholding tax rate applies to dividends paid to a Barbadian company by an Antiguan company?

Under the CARICOM 1994 multilateral double-taxation agreement, ordinary dividends paid by an Antiguan-resident entity to a Barbadian-resident entity attract 0% withholding tax in Antigua. Both Antigua and Barbados are CARICOM member states party to that agreement. Without the treaty, Antigua's domestic WHT rate of 25% would otherwise apply.

What rate applies to interest paid to a UK company from Antigua?

The 1947 UK-Antigua arrangement does not include an interest article, so the domestic Antiguan withholding rate of 25% applies to interest paid to UK recipients. The arrangement covers dividends and royalties at 0%, but interest falls outside its scope. A UK company receiving Antiguan-source interest therefore faces the full statutory 25% unless another mechanism applies.

How does a non-resident claim treaty relief from Antiguan withholding tax?

A non-resident recipient claiming a reduced WHT rate under a treaty must typically demonstrate residence in the treaty-partner jurisdiction to the Antiguan payer. The Inland Revenue Department administers WHT collection and issues a Certificate of Deduction of Withholding Tax to confirm amounts withheld. The payer withholds at the applicable treaty rate and remits to the IRD. Affected parties should engage a qualified tax professional for the specific claim procedure.

Has Antigua and Barbuda signed the OECD Multilateral Instrument (MLI) and how does that affect existing treaties?

Antigua and Barbuda signed the OECD MLI on 18 June 2025, but the instrument is not yet in force for Antigua as of mid-2026. Until the MLI takes effect domestically, existing treaties (CARICOM 1994, UK 1947, UAE 2017) continue without the MLI's BEPS modifications, such as principal-purpose tests or limitation-on-benefits clauses. Once ratified, the MLI will overlay covered treaties with those anti-avoidance provisions.

Tax Treaty Relief in Antigua and Barbuda — Rates, Rules & Filing

Antigua and Barbuda occupies an unusual position in international tax: personal income tax was abolished in April 2016 [1], meaning individuals resident in the country face no domestic income levy on which a foreign treaty credit could operate. For individuals, cross-border treaty relief therefore has limited direct application to Antiguan-resident income. The treaty network remains significant, however, for corporate entities and non-residents receiving Antigua-source payments subject to withholding tax (WHT).

Why does Antigua and Barbuda have a treaty network if there is no personal income tax?

The answer lies in corporate-side taxation. Resident companies pay corporation tax at a standard rate of 25% on net profits, with reduced rates of 22.5% for qualifying banks and 10% for insurance, petroleum, and telecommunications operators [2]. Non-resident companies and individuals that earn income sourced in Antigua and Barbuda are subject to WHT at the statutory rate of 25% on dividends, interest, and royalties remitted abroad [2]. A development-loan exception allows WHT at 10% where a non-resident lends money at arm's length to finance qualifying development activity, subject to approval by the Commissioner of Inland Revenue [2]. Treaties reduce or eliminate these WHT rates for residents of treaty-partner jurisdictions, and TIEAs give the Antiguan competent authority and its partners a legal basis for exchanging financial account data. The absence of personal income tax means that individuals resident in Antigua generally have no Antiguan tax from which a foreign-country relief mechanism would run, but the corporate and WHT framework makes treaty access commercially meaningful for cross-border investors and inbound payment recipients. Individuals and entities seeking jurisdiction-specific guidance should consult a qualified tax professional and may find the Antigua and Barbuda country overview a useful starting point.

What does the CARICOM multilateral double-taxation agreement cover?

The Agreement Among the Governments of the Member States of the Caribbean Community for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion was signed in St. Michael, Barbados on 6 July 1994 and entered into force on 30 November 1994 [3]. Antigua and Barbuda is an original party. The agreement operates on a source-country principle: Article 5 provides that income of whatever nature accruing to a person shall be taxable only by the member state in which the income arises, except for categories that are expressly assigned elsewhere in the agreement [3]. This is structurally distinct from most OECD-model treaties, which primarily assign residence-country taxing rights and allow source-country WHT up to an agreed cap.

For dividends, Article 11 of the CARICOM agreement assigns exclusive taxing rights to the residence state of the recipient, which in practice means the source state (including Antigua) must reduce its WHT to 0% on ordinary dividends paid to a resident of another CARICOM member state [3]. Preference share dividends, interest, royalties, and management fees paid intra-CARICOM are capped at a maximum of 15% in the source state [3]. This represents a reduction from Antigua's domestic 25% rate for those categories. Because Antigua imposes no personal income tax on residents, the source-country-only principle primarily affects corporate entities: an Antiguan company paying interest to a Barbadian company, for example, withholds at no more than 15% under the treaty rather than 25% under domestic law.

The CARICOM agreement has not been substantially amended since 1994. Commentators note it predates modern BEPS concepts such as principal-purpose tests or permanent-establishment definitions [4]. Member states currently participating include Antigua and Barbuda, Barbados, Belize, Dominica, Grenada, Guyana, Jamaica, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, and Trinidad and Tobago, among others. Antigua and Barbuda signed the OECD Multilateral Instrument (MLI) on 18 June 2025 [5]; the MLI is not yet in force for Antigua, so its principal-purpose test and other BEPS measures do not yet overlay the CARICOM agreement or other Antiguan treaties.

| Treaty / mechanism | Partner(s) | Dividends WHT | Interest WHT | Royalties WHT | In force |
|---|---|---|---|---|---|
| CARICOM DTA 1994 | 10+ CARICOM states | 0% (ordinary) / max 15% (preference) | max 15% | max 15% | 30 Nov 1994 |
| UK arrangement 1947 | United Kingdom | 0% | domestic rate | 0% | 30 Jan 1948 (amended 1968) |
| UAE DTA 2017 | United Arab Emirates | 0% | 0% | domestic rate | 24 Feb 2022 |
| No treaty (domestic) | All other countries | 25% | 25% (10% dev loans) | 25% | n/a |

How does the UK arrangement apply?

The arrangement between Antigua and Barbuda and the United Kingdom was signed on 19 December 1947 and entered into force on 30 January 1948 [6]. It was amended by a supplementary arrangement on 5 March 1968, extending application to corporation tax. Under the arrangement, the maximum WHT Antigua may impose on dividends and royalties paid to UK residents is 0%, meaning a UK-resident recipient of Antiguan-source dividends or royalties is relieved entirely from Antiguan WHT [6]. The arrangement does not contain a specific article on interest, so domestic Antiguan rates (25%) apply to interest payments to UK recipients absent other relief [6]. This is a materially older instrument and does not incorporate modern BEPS protections; it predates OECD model provisions on limitation of benefits and principal-purpose testing by several decades. Practitioners managing Antigua-UK cross-border flows should verify that the arrangement's scope covers the relevant income type before relying on the 0% rate.

How does the UAE double-taxation treaty apply?

Antigua and Barbuda and the United Arab Emirates signed a comprehensive income-tax treaty on 15 January 2017 [5]. It entered into force on 24 February 2022 and is the most recent bilateral DTA in Antigua's network. Under this treaty, the WHT rate on dividends paid to UAE residents is 0% and the rate on interest is 0%, with both countries using the credit method to resolve any remaining double-tax exposure [5]. Royalties are not covered by a treaty-reduced rate under this agreement, meaning domestic Antiguan WHT rates would apply. The UAE itself does not impose a personal income tax, so residents of the UAE receiving Antiguan-source dividends or interest benefit from a zero-WHT corridor in both directions.

What TIEAs and automatic exchange frameworks are in place?

Alongside its DTA network, Antigua and Barbuda has signed 18 Tax Information Exchange Agreements with Australia, Belgium, Denmark, Faroe Islands, Finland, France, Greenland, Iceland, Ireland, Liechtenstein, Netherlands, Netherlands Antilles, Norway, Portugal, Sweden, the United Kingdom, the United States, and Aruba [7]. TIEAs do not reduce WHT rates but give the Antiguan competent authority a legal basis to exchange information on request with partner jurisdictions. The US-Antigua TIEA, for example, supports the Internal Revenue Service's ability to request account data on US persons holding assets in Antigua; it does not replicate the WHT-reduction benefits of a full DTA.

For automatic exchange, Antigua and Barbuda signed the Multilateral Competent Authority Agreement on the Common Reporting Standard (CRS MCAA) in 2015 and commenced automatic exchange of financial account information in September 2018 [8]. The domestic legal framework is the Automatic Exchange of Financial Account Information Act, which was amended in 2025 to address deficiencies identified in the OECD's peer-review process [8]. Financial institutions in Antigua are required to conduct due diligence on account holders, identify non-residents, and report account balances, interest, dividends, and proceeds to the Antiguan competent authority for onward transmission to treaty partners. Antigua also signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting on 28 January 2024, extending exchange obligations to multinational group tax data [5]. The EU removed Antigua and Barbuda from its list of non-cooperative jurisdictions for tax purposes in October 2024, reflecting improved compliance with transparency and exchange standards [9].

Individuals or entities with cross-border filing obligations involving Antigua and Barbuda should consult a qualified tax professional familiar with both the relevant treaty terms and the applicable domestic WHT rules before structuring any payment flow.

Tax Treaty Relief in Antigua and Barbuda

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