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

Trinidad and Tobago

A. Progress in the implementation of the minimum standard

Trinidad and Tobago has 16 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.

Trinidad and Tobago has not signed the MLI.

Trinidad and Tobago indicated in its response to the Peer Review questionnaire that it intends to implement the minimum standard through the inclusion of the preamble statement and the PPT combined with the simplified LOB.

In its response to the Peer Review questionnaire, Italy indicated that its agreement with Trinidad and Tobago did not give rise to material treaty shopping concerns for Italy.

B. Conclusion

Trinidad and Tobago is currently developing a plan, in consultation with the Secretariat, for the implementation of the minimum standard in its agreements with Brazil, Canada, China (People’s Republic of), France, Germany, India, Italy, Luxembourg, Norway, Spain, Sweden, Switzerland, and the United Kingdom.

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.

Summary of the jurisdiction response – Trinidad and Tobago

 

	1.Treaty partners	2. Compliance with the standard	3. Signature of a complying instrument	4. Minimum standard provision used
1	United States	No	No

Other agreements

 

	1.Treaty partners	2. Inclusive Framework member
1	CARICOM Agreement treaty partners (Antigua and Barbuda, Barbados, Belize, Dominica, Grenada, Guyana*, Jamaica, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines)	Yes (Antigua and Barbuda, Barbados, Belize, Dominica, Grenada, Jamaica, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines) No (Guyana*)
2	Brazil	Yes
3	Canada	Yes
4	China (People’s Republic of)	Yes
5	France	Yes
6	Germany	Yes
7	India	Yes
8	Italy	Yes
9	Luxembourg	Yes
10	Norway	Yes
11	Spain	Yes
12	Sweden	Yes
13	Switzerland	Yes
14	United Kingdom	Yes
15	Venezuela*	Yes