Focus on Barbados Budget

<strong>Focus</strong> on
Barbados Budget
2012

Table of contents
Executive summary..................................1
Budget commentary.................................4
Ernst & Young Caribbean tax leaders......14
Barbados tax managers..........................14
Contact information...............................15

Executive summary
Too little too late?
The Honourable Minister of Finance, Christopher Sinckler, presented his third budget against the
backdrop of impending elections and in the context of a fragile Barbados economic recovery. In this
most challenging global economic environment in generations, the Minister was swift to highlight
some constructive developments in the fiscal affairs of the country achieved by his Government. These
included the island’s positive first quarter economic growth, and improvements in our current account
deficit.
Counterbalancing these glimmers of hope, the Minister was forced to acknowledge that stubbornly high
unemployment rates continue unabated, inflation remains above any reasonable medium term target
and the economic outlook remains one of tepid growth and continued deficit spending. Faced with these
multiple threats the Minister attempted to articulate a balanced course between growth and austerity
constructed around a mixture of traditional and novel fiscal measures.
The Central Bank of Barbados’ 2012 first quarter economic review characterised the performance in the
economy as stable with marginal growth. However, we believe that growth will continue to be sluggish
given the weakened tourism sector and the need for Government to implement sharper cuts to fiscal
spending. Tourism continues to be a major driver of economic activity, contributing 12% of GDP in 2011
and approximately 40% of the Island’s total foreign exchange earnings. While the review for the first
quarter signals increased tourist arrivals; shorter stays, reduced spending and declining cruise ship
arrivals have reduced the current account inflows from the sector.
The fragility of the economy may also be considered in terms of the levels of Gross International Reserves
(weeks of imports) which have steadily declined since 2009 (see graph below). While the first quarter
shows upward movement from 15 weeks (December 2011) to 16 weeks (March 2012) approximately, it
must be noted that one level is measured as at December (half way through the tourism season), and the
other measured as at March (the end of our main tourism season).
1 <strong>Focus</strong> on Barbados Budget 2012

Executive summary cont’d
Beyond the next few months, the increasing debt balance and the consequential increasing cost of debt
(higher interest) will exert more pressure on foreign reserves. On a positive note, just under one third of
Government’s debt is denominated in foreign currencies. However, the Government continues to finance
a significant portion of its rising debt from domestic sources, primarily NIS, private and non-bank entities
through the issuance of treasury bills and debentures.
During the fiscal period, Government implemented a revised method of calculating the debt-to-GDP
statistic. By consolidating National Insurance (“NIS”) with Government, the revised ratios as at March
2012 are as follows:
Gross Central Government debt to GDP (%)
(NIS)
2005 2006 2007 2008 2009 2010 2011
49 49 53 57 66 74 78
Source: Central Bank of Barbados, Economic Review March 2012
While the revised calculation is based on a recommendation of major international economic institutions,
many analysts argue that it distorts the true economic position of Government. Though not readily
comparable, consider the Central Bank’s Debt-to-GDP ratio of 97% (based on previous calculation) as at
December 2011 compared to the March 2012 ratio of 78% (based on revised calculation).
Similar to budget presentations in the past, the Minister addressed a number of policies some more
material and consequential than others. In our view among the most significant measures were: the
reduction in personal tax rates to 17.5% for the first income band; the imposition of a national greening
levy; the changes in the taxation of the international business sector; the clarification and liberalisation of
immigration policy for high net worth individuals; the divestment by public offering of certain Government
owned entities; the introduction of incentives for listing on the junior stock exchange and the utilization of
NIS funding for strategic investments.
In terms of personal taxation the Minister acknowledged the removal of the personal allowances available
by custom for the middle class had the effect of decreasing disposable income. Yet the Government did
not see it prudent to reintroduce the discontinued incentives which the Minister stressed was subject to
some measure of abuse in the past. Instead the Government opted to increase the lower threshold of
taxation from $24,200 to $30,000 and reduce the tax rate on the first $30,000 of taxable income to
17.5% to deliver a modicum of relief to taxpayers with an expected loss to the Treasury of $29 million. This
gesture was partly offset by the $15 million imposition of a national greening levy on individuals at rates
ranging up to 0.25% aimed at defraying the rising cost of sanitation services. We found it interesting that
the Administration sought it fit to levy the green fund imposition on individuals rather than on businesses
as is done in other Caribbean territories such as Trinidad & Tobago where a similar levy called the Green
Fund Levy is principally imposed on corporate tax payers. In addition, the net benefit to tax payers created
by these two opposing measures seems relatively immaterial and is unlikely to offer the level of tax payer
relief promoted.
<strong>Focus</strong> on Barbados Budget 2012
2

Executive summary cont’d
The Minister clearly articulated the challenges faced by the International Business Sector by certain
changes to the Canadian domestic tax rules that effectively eliminated Barbados’ previous advantage over
its zero tax Caribbean neighbours. Our Firm participated in some of this analysis and discussions and,
although the reduction in the lower rate of tax for international business vehicles on income over $30
million to 0.5% in 2012 and 0.25% in 2013 is a bitter pill to swallow, it was essential to forestall what may
have been a more significant migration of Canadian owned businesses from Barbados. We also welcome
the clarification of our immigrations laws which should help make the island more friendly to credible
foreign investors and raise much needed fees and offer trickle down economic benefits for the
Barbados economy.
In these difficult economic times it is not unusual for governments to seek unconventional means of raising
revenues. In this context, the Minister announced the full or partial divestment of three Government owned
entities: the Grantley Adams International Airport, the Oil Company and the Barbados Port Authority,
by way of public offerings. This move is welcomed and if properly executed should have the cascading
benefit of stimulating the island’s stagnant capital markets, raising Government revenue and improving the
corporate governance of these entities.
In similar vein to our Caribbean neighbours, Jamaica and Trinidad & Tobago, the Government announced
new incentives to stimulate listing of small and medium sized entities on the junior stock exchange. A
similar measure was introduced in Jamaica and has been met with the successful listing of over ten
companies. Conversely, in Trinidad & Tobago the incentive has just been enacted and is now being
launched. Although the Barbados tax incentives appear attractive on the surface, the conditions placed
upon significant ownership by one shareholder of no more than 25% and a minimum of 50 shareholders
appear too restrictive and may act as a disincentive for family owned businesses to go public. By contrast
both Jamaica and Trinidad & Tobago allow for majority control by certain founding shareholders, whilst at
the same time mandating at least 20% - 30% of the shares be held by the investing public for benefits to
be obtained.
Perhaps the most novel approach articulated by the Minister in this budget is the selective use of NIS
surpluses for national strategic type investments. On the one hand this is certainly an innovative approach
and arguably leads to more long term investment options for an NIS, which the Minister stated is in an
advantageous surplus situation. On the other hand, analysts have been quick to point out the dangers of
Government directed investment of pensioners’ funds.
In his third budget presentation, the Minister perhaps went further than he ever did before in attempting
to strike the crucial balance between growth and austerity so necessary at this stage in the country’s
economic cycle. Certainly there were various constructive measures discussed and passed especially
concerning the island’s international business sector and we generally favor the attempts to reinvigorate
the capital markets. Whether these steps are sufficient to stimulate the growth and employment the island
so desperately needs and whether they have come in time to placate an increasingly impatient electorate
is a question that would soon be answered.
3 <strong>Focus</strong> on Barbados Budget 2012

Budget commentary
Personal taxation
Personal tax threshold and personal income tax rate
Under the current income tax rules, the first BDS$24,200 of an individual’s taxable income is subject to tax
at the rate of 20%. The Minister proposed that effective 1 August 2012, the tax threshold will be increased
from BDS$24,200 to BDS$30,000. Additionally, the effective tax rate applicable to that threshold will be
decreased from 20% to 17.5%.
Comment
The Minister expressed that the implementation of this measure is meant to “strike a delicate balance”
between the relief desired by individuals and the prevention of the abuse of the tax free allowances
which were previously removed. To illustrate the impact of this measure, the table below outlines the
tax savings envisioned for individuals earning in one instance BDS$30,000 and in another BDS$60,000,
assuming that the changes are effective for an entire income year.
<strong>Focus</strong> on Barbados Budget 2012
4

Budget commentary cont’d
Before After Change Before After Change
Employment income 30,000.00 30,000.00 - 60,000.00 60,000.00 -
Less: Personal
allowance
(25,000.00) (25,000.00) - (25,000.00) (25,000.00) -
Taxable income 5,000.00 5,000.00 - 35,000.00 35,000.00 -
Taxes payable
$24,200 @ 20% 1,000.00 4,840.00
$30,000 @ 17.5% 875.00 5,250.00
Balance @ 35% - - 3,780.00 1,750.00
1,000.00 875.00 125.00 8,620.00 7,000.00 1,620.00
National Greening Levy
Up to Bds$25,000 X
0%
- - - -
Between $25,000 and
$50,000 X 0.1%
- 30.00 -
Between $50,000 and
$100,000 X 0.15% - - - 90.00
Over $100,000 X
0.25%
- - - -
- 30.00 (30.00) - 90.00 (90.00)
Net change 95.00 1,530.00
It is interesting to note that although the savings from this measure can vary among the lower income earners, the
maximum savings any individual can expect to realize from this reduction in tax is BDS$1,620. This is outlined below.
Taxable amount Tax rate Tax effect
$24,200 20.0% $4,840
($30,000 less $24,200) or $5,800 35.0% 2,030
Sub-total 6,870
$30,000 17.5% (5,250)
Net effect $1,620
This measure marginally counteracts the increased tax burden which followed from the removal of the tax free allowances
for travel and entertainment, as well as the removal of the allowances for investments in credit unions, shares in new
companies, and mutual funds. As seen above, while this measure does not negate the current burden felt by taxpayers, it
does provide minimal relief to middle income earners.
5 <strong>Focus</strong> on Barbados Budget 2012

Budget commentary cont’d
National Greening Levy
Against a backdrop of the production of double the volume of solid waste in the past twelve years, the
Minister has proposed the implementation of a “National Greening Levy”. This levy is proposed to assist
in meeting the costs associated with the treatment of the garbage produced in Barbados on a daily basis.
The levy will be imposed on the salaries of Barbadian workers and will be collected through the National
Insurance Scheme to be remitted to the Consolidated Fund.
The levy will be imposed as follows:
• Persons earning up to BDS$25,000 per year - 0%
• Persons earning between BDS$25,000 and BDS$50,000 per year - 0.1%
• Persons earning between BDS$50,000 and BDS$100,000 per year - 0.15%
• Persons earning above BDS$100,000 per year - 0.25%
Comment
While this measure will have the effect of reducing the disposable income produced by the decrease in
personal taxation, the question arises as to whether this proposed National Greening Levy will present
an unnecessary administrative burden and costs to employers and the National Insurance Department
who must now process this levy separately. With the introduction of the levy, there will now be added
withholding and remitting requirements together with the responsibility of completing the requisite
forms. These processing requirements in addition to the costs associated with the administration of this
levy are reminiscent of the surcharge and stabilization tax of the early 1990’s. In light of these factors,
the issue arises as to whether the levy is worth the effort it will require.
“Ounce of Prevention” Tax Credit
The Minister proposed the implementation of a tax credit for up to BDS$750 in respect of a comprehensive
annual medical examination for persons 40 years and over. The allowance may be claimed on filing of
the individual’s tax returns and should be accompanied by an electronic copy of a certificate verifying the
procedure was done and signed by a registered medical practitioner.
Comment
This measure is well intentioned given the rise in chronic non-communicable diseases. The tax credit
is aimed at encouraging individuals over the age of 40 to be pro-active in respect of early detection.
It is interesting to note that this incentive may be subject to abuse by taxpayers who receive a
reimbursement of this amount from their medical insurance and who can also make a claim for a credit
under this proposal. Administrative policies will need to be instituted to prevent this.
<strong>Focus</strong> on Barbados Budget 2012
6

Budget commentary cont’d
International business
The Minister of Finance in his presentation proposed that the International Business Companies Act, the
Societies with Restricted Liability Act and the International Financial Services Act be amended to change
the tax rate applicable to the highest band of income earned by the international business companies
(“IBCs”), international societies with restricted Liability (“ISRLs”) and international financial services
companies (including international banks). Currently, under this legislation, a tax rate of 1% applies to
all income over BDS$30,000,000. However, the tax rate applicable to this band of taxable income (over
$30,000,000) for income year 2012 will be reduced to 0.5%. This rate will be further reduced to 0.25% for
income year 2013.
It is proposed that the tax schedule in the aforementioned legislation will be amended as follows:
2012 2013
Taxable Income (BD$) Tax Rate (%) Tax Rate (%)
0 – 10,000,000 2.5 2.5
10,000,001 – 20,000,000 2.0 2.0
20,000,001 – 30,000,001 1.5 1.5
Over 30,000,001 0.5 0.25
Comment
These proposed amendments are in response to the external threats faced by the International
Business Sector as a result of certain changes to the Canadian domestic tax rules that effectively
eliminated the previous advantage that Barbados had over its zero tax Caribbean neighbours.
The international business sector has been a major driver of our economy for some time. As such,
we need to be proactive in dealing with external challenges and continually seek to create innovative
ways to attract new foreign investors and retain existing investors. The proposed amendments should
increase the attractiveness of Barbados as a jurisdiction for conducting international business.
However, experience has shown that tax incentives alone are not enough. Government also needs to
put an end to bureaucratic obstacles to doing business in Barbados and to create a service friendly
environment to attract major foreign investment and generate revenue for Barbados.
Foreign currency earning credit
The Minister of Finance has proposed that the range of “qualifying overseas professional services” that are
eligible for the foreign currency earnings credit (“FCEC”) under the provisions of the Barbados Income Tax
Act would be expanded to include exploration, extraction and mining, oil and gas activities, licensing and
sub-licensing of intellectual property, and shipping services.
7 <strong>Focus</strong> on Barbados Budget 2012

Budget commentary cont’d
Comment
The Barbados Income Tax Act provides that where a person, including a company or an individual,
carrying on business in Barbados derives assessable income from fees in respect of qualifying overseas
professional services, in computing the tax payable on such income, a FCEC would be applied against
the tax otherwise payable.
In an effort to stimulate the productive sector, it has been proposed that the range of qualifying
overseas professional services eligible for the FCEC be expanded to include exploration, extraction
and other mining, oil and gas activities, licensing and sub-licensing of intellectual property and
shipping services.
Currently, the majority of the double taxation treaties that Barbados has with its major trading
partners, including Canada, the United States and the United Kingdom, contain provisions which
prohibit entities with special incentives, such as IBCs and ISRLs, from taking advantage of either all of
or some of the benefits of these treaties. Therefore, investors seeking to provide the above services
outside the Caricom market can alternatively set up a regular Barbados company to claim treaty
benefits and also take advantage of the FCEC provided under the Barbados Income Tax Act. As a result,
a person may be able to substantially reduce his overall tax liability.
The table below illustrates how the FCEC is calculated for a company.
Profits from FCE as a % of total profits
Rebate of income tax as a % of
income tax on net profits from FCE
Effective Tax Rate
20% and under 35% 16.25%
20% but under 41% 45% 13.75%
41% but under 61% 64% 9.00%
61% but under 81% 79% 5.25%
81% and over 93% 1.75%
<strong>Focus</strong> on Barbados Budget 2012
8

Budget commentary cont’d
The calculation is based on a pro-rated formula as follows:
FCE x P
TE
FCE – Foreign currency earnings
TE – Total gross earnings from all sources
P – Net profits from all sources
Therefore, depending on the level of foreign currency earnings derived by a Barbados company from
outside of Barbados and Caricom in respect of the provision of qualifying overseas professional
services, the FCEC can reduce its Barbados corporation tax payable to a low effective rate of tax.
Example
A qualifying oil and gas exploration company, engaged in the provision of services to companies outside
of the Caricom market, has foreign currency earnings of $30,000, net profit before tax of $15,000 and
total gross earnings of $50,000. Based on the above formula, the FCEC is calculated as follows:
30,000 x 15,000 = 9,000 = 60% of total profits
50,000
Note that the FCEC is 64% rebate on income tax, therefore:
Tax on foreign currency earnings – $9,000 x 25% (tax rate) =$2,250
Rebate of income tax – 64% [$2,250 x 64%] =$1,440
Immigration
The Minister of Finance has proposed a number of immigration policies which will allow certain qualifying
non-nationals to obtain special entry permits. A fee structure was proposed for these permits.
Comment
This proposal is welcomed as it will encourage certain qualifying non-nationals who are parents/
grandparents of citizens of Barbados and high net worth individuals to establish their business and/or
their place of abode in Barbados. The granting of special entry permits to these non-nationals would
allow them to move freely in and out of Barbados without any time constraints.
The immigration measures proposed for high net worth individuals combined with the availability of a
FCEC on the remittance of foreign income to Barbados, the benefits of the Barbados/United Kingdom
tax treaty and the absence of capital gains tax and inheritance tax should increase the attractiveness of
Barbados to such high net worth individuals, especially from the United Kingdom.
9 <strong>Focus</strong> on Barbados Budget 2012

Budget commentary cont’d
Property transfer tax
The Minister of Finance has proposed the removal of property transfer tax when the shares of a Barbados
company are transferred during a corporate reorganization of a group of companies and with no change of
beneficial ownership.
It was noted that that this proposal should become effective from 1st August.
Comment
It is noted that section 6(1A.2) of the Property Transfer Tax Act already provides for an exemption of
property transfer tax in respect of a transfer of property consisting of shares the value of or the amount
of consideration of which exceeds $50,000 and where there is no change in the beneficial ownership of
the shares. This exemption was effective since 1999.
We assume that this proposal is not redundant and instead is intended to provide for greater clarity
with respect to the application of the property transfer tax exemption.
Excise taxes
The Minister sought to address the reported downturn in new vehicle sales that confronted the
Automotive Industry as a result of the constant increases in the manufacturer and other related costs and
consequently the increase in the Cost Insurance and Freight (“CIF”) value of motor vehicles imported into
Barbados. This was done through a two-pronged approach, which involved increasing the chargeable value
(“CV”) of vehicles on which the excise tax is computed. The CV comprises the CIF value plus applicable
import duty. Second, the excise tax was reduced by 25% on the vehicles that qualify.
Comment
While these measures will result in a reduction of excise taxes, there is uncertainty as this tax is applied
not only by virtue of the CV but also by reference to the engine capacity of the vehicle. We believe,
based on the Minister’s opening remarks, that this benefit will only be available to vehicles that fall in a
specified category. Also, we are uncertain whether the reduction is comprised of a reduction of the rate
by 25 percentage points or rather a reduction of the existing rate of 25% (i.e. 75% of the current rate).
The table below provides an example in the case of a vehicle falling under tariff heading 87.03 and of an
engine capacity of 1600 cc or less.
<strong>Focus</strong> on Barbados Budget 2012
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Budget commentary cont’d
Rate of tax Before Reduction in rate by 25% 75% of current rate
Engine Capacity 1600 CC 1600 CC 1600 CC
CIF Value 35,000.00 35,000.00 35,000.00
Duty 45.00% 15,750.00 15,750.00 15,750.00
Chargeable value 50,750.00 50,750.00 50,750.00
Excise Tax 46.95% 23,827.13
Reduced by 25% 21.95% 11,139.63
75% of current rate 35.21% 17,869.08
Value Added Tax 17.50% 13,051.00 10,830.69 12,008.34
Total taxes
Duty 15,750.00 15,750.00 15,750.00
Excise tax 23,827.13 11,139.63 17,869.08
VAT 13,051.00 10,830.69 12,008.34
52,628.13 37,720.32 45,627.42
It is important to note that this facility applies only to new vehicles and this could spell a downturn for
the used car industry.
With respect to the increase in the excise tax rate on locally manufactured vehicles to make the rate
compatible with that for imports, this measure was expected as it was only a matter of time before
Barbados had to correct that violation of the World Trade Organisation (“WTO”) rules arising on the
inequity of the application of domestic taxes to imports and locally manufactured goods.
Customs duty
The Minister announced a reduction in the rates of customs duties on the importation of electric cars and
hybrids and solar powered vehicles.
Comment
It is hoped that these rate reductions will result in attractive pricing which will entice Barbadian
consumers to opt for “green” motor vehicles.
11 <strong>Focus</strong> on Barbados Budget 2012

Budget commentary cont’d
Greening the Barbados economy
Business incentives
The Minister in his presentation proposed to implement incentives for businesses generating and
distributing electricity from a renewable energy source, or producing, distributing and/or installing
renewable energy systems for electricity generation and energy efficient products.
The proposed business incentives include:
• Low-interest loans,
• Duty and VAT exemptions,
• VAT zero rating,
• Income tax holidays,
• 150% deduction for tax purposes of:
• loan interest in relation to qualifying institutions facilities,
• training expenditures,
• marketing,
• product development, and
• Deduction for tax purposes of funds spent by individuals on training received from
approved institutions.
Comments
The Government must be applauded for these bold incentives which will make Barbados an attractive
environment for businesses in the renewable energy sector. However, it is not clear what criteria a
business must meet in order to be considered eligible for these incentives. Additionally, it is anticipated
that the legislative and administrative requirements associated with these incentives will prove to be
extremely cumbersome.
Investor incentives
The Minister of Finance has also proposed incentives for investors in businesses generating and distributing
electricity from a renewable energy source, businesses producing renewable energy systems for electricity
generation and energy efficient products.
The proposed investor incentives include:
• Withholding tax exemptions in respect of interest and dividends,
• Corporation tax holidays for venture capital funds,
• Deductibles in respect of contributions to venture capital,
• Exemption from all taxes in respect of household income earned from the sale of electricity.
<strong>Focus</strong> on Barbados Budget 2012
12

Budget commentary cont’d
Comments
These investor incentives indicate the Government’s commitment to expanding the renewable energy
and energy efficient sectors and will no doubt entice investors to invest in Barbadian businesses.
However, clarification is needed as to what criteria an investor must meet in order to qualify for these
incentives. Once again, the legislation and administration required to give effect to these incentives will
no doubt be difficult to implement.
Land tax
Increase in rebate for pensioners
The Minister of Finance proposed an increase in the rate of rebate of land tax for pensioners from 50%
to 60%.
Comment
This measure is welcomed. The start of a new evaluation cycle in 2011 to 2012 saw an increase in
property values which created a rise in tax assessments. This rebate will compensate for that
increase in light of the currently depressed real estate market. Moreover, it will have a negligible
impact on revenues.
Amnesty
The Minister outlined that there were arrears owed to the Land Tax Department which dated back to 1982.
It was proposed that in an effort to reduce the high level of arrears, an amnesty would be introduced in
respect of tax years 1982 to 2011. The following conditions would be attached to the amnesty:
• The amnesty would be for a period of 30 days commencing 2 July 2012 to 31 July 2012,
• The amnesty would allow for a 100% waiver of both the penalty and interest dependent on the full
amount of the principal being paid in a one-off payment for the respective year due,
• There would be no extensions of the amnesty.
Comment
As with the Value Added Tax, National Insurance and corporation tax amnesties implemented in
previous years’ Budgetary Proposals, it is expected that this amnesty will result in increased revenues.
However, any revenue projections must take into account the fact that this amnesty is proposed for one
month only and will not be extended. Therefore, though this measure is laudable, the question arises as
to whether the time period allotted will be sufficient to create an impact on government revenues.
13 <strong>Focus</strong> on Barbados Budget 2012

Ernst & Young Caribbean tax leaders
Wade M. George, BA, LL.M
Regional Tax Service Line Leader
Partner, Tax Services
Ernst & Young Services Ltd.
Trinidad
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Maria Robinson, BBA, CA
Partner, Tax Services
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Dominique Pepin, LL.B, Dip. Tax.
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Allison Peart, CA
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Barbados tax managers
Gail Ifill, LL.B.
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Toni Jackman, CGA
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Rhyna Franklin, MBA
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Tamika Cumberbatch, BSc., CPA, LL.M
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Ray Jackman, Bsc.
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Javier Lemoine, LL.B, LL.M
Manager - Head of Latin American Business Development
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Barbados
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<strong>Focus</strong> on Barbados Budget 2012 14

Contact information
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15 <strong>Focus</strong> on Barbados Budget 2012

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