There are no thin-capitalization rules in Saint Lucia.
However, deductibility of interest on loans from shareholders or their associates, provided to a controlled company, may be restricted or disallowed by the tax authorities if they observe that the interest paid or the rate of interest charged is unreasonable as compared to commercial rates.
Controlled company is a resident company which is owned and controlled by not more than 5 shareholders (excluding the Government and any other controlled company). A company is deemed to be owned and controlled by not more than 5 shareholders if such shareholders beneficially own shares carrying, directly or indirectly, the right to exercise or receive more than 50% of the voting power or dividends or capital distribution in the company.