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5.5. Source Rules with Respect to Income Derived by Non-Residents

Income earned by non-residents through a permanent establishment (‘PE’) from sources in Saint Lucia is subject to tax in the country.

The following income is deemed to have accrued from sources in Saint Lucia:

  • income from employment in Saint Lucia
  • interest earned from a resident or attributable to a permanent establishment in Saint Lucia
  • income earned from property located in Saint Lucia
  • income earned from the provision of services including personal, technical or managerial services in Saint Lucia
  • income earned from any other source of income which is considered to be situated in Saint Lucia

Taxes collected through withholding tax are deemed to be the final tax on such income. Income subject to withholding tax includes interests, royalties, services fees, etc.

Effective from 1 January 2019, income from following sources is considered as foreign-sourced income:

  • Profits derived from a permanent establishment located outside Saint Lucia;
  • Profits derived from immovable property situated outside Saint Lucia;
  • Interest paid by non-residents which is not borne by a Saint Lucia PE or charged against property situated in Saint Lucia;
  • Income derived from investment in securities issued by a non-resident;
  • Management charges paid by a non-resident from a source outside Saint Lucia, where the costs are not attributable to a PE in Saint Lucia;
  • Royalty payments made by a non-resident PE to a resident PE; and
  • Any other source of income which is deemed to accrue from a source outside Saint Lucia pursuant to a Double Taxation Agreement.

Foreign-sourced income is not subject to tax is Saint Lucia. It is further clarified that payments made to non-residents in relation to the earning of such foreign-source income are not subject to withholding tax in Saint Lucia.