Does The Bahamas have any double-tax treaties?

No. The Bahamas has no comprehensive double-taxation agreements (DTAs). Because the jurisdiction levies no personal income tax, corporate income tax, or capital-gains tax, there is no Bahamian tax from which treaty relief could be granted. Cross-border cooperation relies on a network of 31 Tax Information Exchange Agreements (TIEAs), which share taxpayer information but do not reduce source-country withholding rates.

How many TIEAs has The Bahamas signed and with which countries?

The Bahamas has signed 31 TIEAs. Partners include the United States (signed 2002, effective 2004/2006), the United Kingdom, Canada, Australia, Germany, France, Spain, the Netherlands, Japan, India, China, South Africa, Monaco, San Marino, Guernsey, Aruba, Malta, and the Nordic group (Norway, Sweden, Finland, Denmark, Iceland, Greenland, and the Faroe Islands). TIEAs enable information exchange but carry no withholding-rate reductions.

Is a US citizen living in The Bahamas protected from US tax by a treaty?

No. There is no US-Bahamas income tax treaty and no US-Bahamas totalization agreement. US citizens and green-card holders remain subject to US worldwide income reporting regardless of where they live. The Bahamas signed a FATCA Model 1 IGA with the US in November 2014, which requires Bahamian financial institutions to report US-person account data to the IRS -- it does not reduce any US tax obligation.

What is the new 15% DMTT and does it affect individuals?

The Domestic Minimum Top-Up Tax (DMTT) enacted November 2024 applies only to constituent entities of MNE groups with global revenue of EUR 750 million or more, effective for fiscal years from 1 January 2024. The rate is 15%, topping up The Bahamas' 0% effective corporate tax to the OECD GloBE minimum. It does not apply to individuals, small businesses, or MNE groups below the EUR 750 million revenue threshold.

How does CRS automatic exchange of information affect accounts held in The Bahamas?

The Bahamas adopted the OECD Common Reporting Standard on a non-reciprocal basis via the Multilateral Convention. Since September 2018, Bahamian financial institutions have reported account information for non-resident account holders to their home-country tax authorities. Individuals resident in CRS-participating countries who hold Bahamian accounts should assume their home tax authority receives annual account balance and income data.

Tax Treaty Relief in Bahamas — Rates, Rules & Filing

Does The Bahamas have double-tax treaties?

The Bahamas has no comprehensive double-taxation agreements (DTAs) in force. The reason is structural: double-tax treaties exist to prevent the same income from being taxed twice by two different countries. Because The Bahamas imposes no personal income tax, no corporate income tax, and no capital-gains tax, there is no Bahamian tax to relieve. PwC's Worldwide Tax Summaries confirms: "Since no income taxes are imposed on individuals in The Bahamas, foreign tax relief is not relevant in the context of The Bahamas taxation." [1] The absence of DTAs is therefore a direct consequence of the tax structure, not a policy gap. Residents and businesses should not expect treaty-rate reductions on income received from abroad, and a qualified tax professional familiar with cross-border structures can identify which source-country rules apply in any specific situation.

Mechanism	Status in The Bahamas	Purpose
Comprehensive double-tax treaties (DTAs)	None in force	No income tax to relieve
Tax Information Exchange Agreements (TIEAs)	~31 in force (US, UK, Canada, Nordics)	On-request information exchange
FATCA (Model 1 IGA)	In force since 2014	Automatic reporting of US-held accounts
Common Reporting Standard (CRS)	Active since 2017	Automatic financial-account exchange
Crypto-Asset Reporting Framework (CARF)	Committed; first exchange 2027-2028	Automatic crypto-account exchange
Domestic Minimum Top-Up Tax (DMTT)	15%, from 2024	Pillar Two top-up for large MNE groups

What does The Bahamas have instead of DTAs? The TIEA network

In place of comprehensive tax treaties, The Bahamas has built a network of 31 bilateral Tax Information Exchange Agreements (TIEAs). These are narrower instruments: they enable governments to share taxpayer information for the administration and enforcement of their domestic tax laws, but they do not reduce withholding rates or grant residence-based exemptions. The Bahamas Ministry of Finance publishes the complete list. [2] Partners include the United States, United Kingdom, Canada, Australia, Germany, France, Spain, the Netherlands, Japan, India, China, South Africa, and the Nordic group (Norway, Sweden, Finland, Denmark, Iceland, Greenland, and the Faroe Islands), among others. The US-Bahamas TIEA was signed in January 2002; it became effective for criminal tax matters in 2004 and for civil tax matters in 2006. A TIEA does not function as a tax treaty: a Bahamian resident receiving dividends from a German company, for example, still faces German withholding tax at the standard domestic rate of up to 25%, with no treaty to reduce it.

What CRS, FATCA, and CARF obligations apply?

The Bahamas participates fully in the global automatic exchange of financial information regime. Three frameworks are active:

OECD Common Reporting Standard (CRS): The Bahamas adopted CRS via the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Reporting began with the period July-December 2017; first exchanges with partner jurisdictions took place on 30 September 2018. [3] Unusually, the Bahamas elected a non-reciprocal approach: Bahamian financial institutions report account data to foreign tax authorities, but do not receive reciprocal data on Bahamian residents' foreign holdings from all CRS partners.

FATCA Model 1 IGA: The Bahamas signed a Model 1 Intergovernmental Agreement with the United States in November 2014, followed by a Competent Authority Arrangement on 3 July 2017. [4] Bahamian financial institutions identify US persons, collect account information, and report it to the Bahamian competent authority, which transmits it to the IRS. US citizens and green-card holders resident in The Bahamas remain subject to US worldwide income reporting regardless of Bahamian tax residency.

CARF: The Bahamas signed the CARF Multilateral Competent Authority Agreement (CARF-MCAA) on 19 November 2024 and is committed to commencing first exchanges by 2027-2028. [5] From 1 January 2026, Reporting Crypto-Asset Service Providers (RCASPs) operating in The Bahamas are required to collect and retain reportable information on customers. Bahamian-licensed exchanges operating under the Digital Assets and Registered Exchanges (DARE) Act framework are the primary entities in scope.

How does foreign withholding tax affect Bahamian residents with no treaty relief?

Because no DTAs exist, a Bahamian tax resident who receives foreign-source income bears the full weight of source-country withholding taxes with no treaty offset. The Bahamas itself imposes no withholding taxes on outbound payments of any kind - dividends, interest, royalties, and fees all leave The Bahamas at 0%. [1] However, the reverse is not true: dividends paid by a US corporation to a Bahamian resident face up to 30% US Non-Resident Alien withholding; dividends from a UK company face the UK standard withholding rate; similar rules apply in most capital-exporting countries. There is no foreign tax credit mechanism in Bahamian law (because there is no Bahamian income tax against which to credit), so source-country withholding represents a terminal cost. Investors holding portfolios through Bahamian structures should weigh this carefully with a qualified tax professional before structuring cross-border income flows.

What is the Domestic Minimum Top-Up Tax (DMTT) and who is affected?

The Bahamas enacted the Domestic Minimum Top-Up Tax Act on 29 November 2024, the jurisdiction's first direct levy on corporate profits. [6] The DMTT implements Pillar Two of the OECD/G20 Two-Pillar Solution under the Global Anti-Base Erosion (GloBE) Model Rules and is deemed to have retroactive effect from 1 January 2024. Scope: MNE groups with annual global revenue of EUR 750 million or more that have constituent entities resident in, or operating as permanent establishments in, The Bahamas. Rate: 15%, calculated as a top-up from the actual effective tax rate in The Bahamas (which is effectively 0% given no existing corporate income tax) to the 15% GloBE minimum. Neither the Income Inclusion Rule (IIR) nor the Under-Taxed Profits Rule (UTPR) is being implemented. Filing is due within 15 months after the last day of the relevant fiscal year (18 months for the transition year). The DMTT is a Conditional DMTT for fiscal year 2024 - it applies only if another jurisdiction also applies IIR or UTPR to Bahamian profits. As of early 2025, the Bahamas DMTT had not yet received OECD QDMTT (Qualified DMTT) status on the central record of legislation, meaning parent-jurisdiction top-up taxes could still apply. Registration opened on the government's "One Tax Bahamas" portal in early 2026. [6]

What is The Bahamas' OECD and EU listing status?

The Bahamas was removed from the EU list of non-cooperative jurisdictions for tax purposes on 20 February 2024, having been relisted in October 2022. [7] Removal followed the OECD Forum on Harmful Tax Practices (FHTP) converting its economic substance recommendations from "hard" to "soft", allowing the EU Code of Conduct Group to treat the jurisdiction as compliant. As of the February 2026 Council update, The Bahamas is not on the EU blacklist. The jurisdiction is not a signatory to the OECD Multilateral Instrument (MLI), which is unsurprising given the absence of a DTA network that the MLI is designed to modify. Compliance posture can evolve quickly; consult a qualified tax professional for the most current assessment for any specific structure.

For a broader overview of Bahamian jurisdiction context, see The Bahamas country overview.

Tax Treaty Relief in Bahamas

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