Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping

Grenada

A. Progress in the implementation of the minimum standard

Grenada has four tax agreements in force as reported in its response to the Peer Review questionnaire, including the multilateral agreement among the members of the CARICOM concluded with ten treaty partners (the CARICOM Agreement).1 None of those agreements comply with the minimum standard.

Grenada has not signed the MLI.

In its response to the Peer Review questionnaire, Switzerland indicated that its agreement with Grenada did not give rise to material treaty shopping concerns for Switzerland.

B. Conclusion

The CARICOM Agreement does not at this stage comply with the minimum standard and discussions to bring this agreement up to date should be continued.1

1. Revisions to the CARICOM Agreement require an agreement from its eleven treaty partners.

Recommendation

It is recommended that Grenada formulates a plan for the implementation of the minimum standard in its agreements for which no steps have yet been taken and that were concluded with members of the BEPS Inclusive Framework (South Africa and the United Kingdom).

Other agreements

This Table shows the agreements that are not compliant, not subject to a complying instrument, not covered by a general statement on the implementation of the detailed LOB and for which no steps have been taken to implement the minimum standard.

 

	1.Treaty partners	2. Inclusive Framework member
1	CARICOM Agreement treaty partners (Antigua and Barbuda, Barbados, Belize, Dominica, Guyana*, Jamaica, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Trinidad and Tobago)	Yes (Antigua and Barbuda, Barbados, Belize, Dominica, Jamaica, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Trinidad and Tobago) No (Guyana*)
2	South Africa	Yes
3	Switzerland	Yes
4	United Kingdom	Yes