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HMRC internal manual

Double Taxation Relief Manual

Barbados: Agreement not to apply

The agreement does not apply to companies which are entitled to any special tax benefit under the Barbados International Business Companies (Exemption from Income Tax) Act, 1965-50 as in effect on 26 July 1965 or any substantially similar law enacted by Barbados after that date (Article 23).

Benefits under the treaty, such as the reduced rates of withholding tax, etc, are not therefore to be given to such companies.