Change to withholding tax rate on management fees in the Canada-Barbados Tax Agreement

The withholding tax rate on management fees described in paragraph 1 of Article XIII of the Canada-Barbados Tax Agreement is lowered from 15 percent to 5 percent, as a result of the "most-favoured-nation" provision in subparagraph 1(b) of Article XIII of the Agreement. This change has been confirmed by Barbados. In circumstances where the tax withheld on management fees has been in excess of 5 per cent:

• a Barbadian resident taxpayer can complete form NR7-R, Application for Refund of Part XIII Tax Withheld to apply for a refund of non-resident Part XIII tax withheld. The application must be made within two years from the end of the calendar year in which the amount was paid to: International and Ottawa Tax Services Office, Non-Resident Withholding Division, P.O. Box 9769, Station T, Ottawa ON, K1G 3Y4, Canada 
• a Canadian resident taxpayer may write a letter requesting the refund to the Revenue Commissioner within 3 years of a notice of assessment, detailing all the relevant information and should attach all documentary evidence in support of the claim, and send the letter to: The Revenue Commissioner, Barbados Revenue Authority, 6th Floor Treasury Building, Bridge Street, Bridgetown, St. Michael, Barbados.