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9.1. Unilateral and Treaty Based Methods Available for the Elimination or Mitigation of Double Taxation

Taxpayers are eligible for relief from double taxation with respect to their foreign-sourced income in the application of the tax treaties concluded by Guyana.

Unilateral relief is also available in respect of taxes paid in non-treaty countries. For British Commonwealth Countries, 50% of foreign tax credit relief (which is available, where a tax treaty exists) is allowed, whereas in other countries relief of 25% of the foreign tax credit is allowed against the tax liability in Guyana. In all cases, the available relief is capped at the amount of tax due in Guyana on the relevant income.

Below is a summary of the available methods for various income tax streams based on domestic law.

Royalty Copyright OC
Capital Gains OC
Dividends OC
Interest OC
Royalty Patent OC
Sales OC
Service Management OC
Service Technical OC
Royalty Trademark OC

The credit column shows the type of foreign tax credit granted when the receiving country receives a payment.  Four abbreviations are used for the type of foreign tax credit available:

  • NC means no credit but foreign withholding taxes can be deducted.
  • OC means ordinary credit, i.e., credit for foreign withholding taxes (e.g., withholding taxes).
  • IC means indirect credit, i.e., credit for underlying corporate taxes as well as foreign withholding taxes.
  • ND means no credit and no deduction for any foreign withholding taxes incurred.