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4.1. Domestic PE of a Foreign Entity

There is no definition of permanent establishment (PE) under domestic law. A non-resident company is deemed to have a taxable presence in Barbados if it has a branch or agency therein.

A ‘service PE’ is said to be constituted based on the presence of the employees or personnel of a non-resident in Barbados for a specified number of days. The Barbados domestic law does not contain any definition of service PE, however, certain tax treaties signed by Barbados contain service PE clauses. For example, the Barbados-Canada treaty provides that a service PE is constituted when a non-resident enterprise furnishes consultancy services in Barbados, directly or through employees or other personnel engaged by the enterprise, for more than 3 months in a 12-month period.