Guyana Tax Regime

Guyana operates a source- and residence-based corporate income tax system layered over a small, fast-growing petroleum economy alongside a traditional agricultural, mining and services base. Resident companies are taxed on worldwide income; non-residents carrying on a trade or business in Guyana are taxed on Guyana-source income. The headline feature of the regime is its differentiated corporate rate structure — commercial companies (import/distribution, banking, insurance, telecommunications) are taxed more heavily than non-commercial (manufacturing, agriculture, services) companies — combined with a minimum corporation tax on turnover that acts as an alternative minimum for commercial companies. The petroleum sector is governed by separate production-sharing arrangements outside the scope of the general corporate code. Personal taxation is progressive with a relatively high tax-free threshold, and indirect taxation is anchored by a value-added tax administered by the Guyana Revenue Authority.

1.1 Sources

Primary legislation includes the Income Tax Act, the Corporation Tax Act, the Value-Added Tax Act, the Tax Act (administration and collection provisions) and the Income Tax (In Aid of Industry) Act, all administered by the Guyana Revenue Authority.

1.2 Recent developments

Guyana's tax base has broadened rapidly alongside offshore petroleum production, with continued strengthening of Guyana Revenue Authority administration, e-filing capacity and audit resources funded in part by rising petroleum revenues flowing through the Natural Resource Fund. The corporate rate structure — 40% commercial / 25% non-commercial, with a 45% rate for telephone companies — has remained stable, as has the 2% minimum corporation tax on turnover for commercial companies. Government policy continues to favour targeted fiscal incentives (tax holidays, accelerated depreciation and duty concessions) for manufacturing, agro-processing, tourism and information-technology investment outside the capital, alongside incremental modernisation of transfer pricing and international-cooperation provisions consistent with regional peers.

Headline statutory corporate income tax rate for a resident company. Where sub-national (state, provincial, cantonal or municipal) corporate taxes apply, the combined rate reported by the OECD is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

Top marginal statutory personal income tax rate on employment income for a resident individual. Where sub-national (state, provincial, cantonal or municipal) income taxes are a standard part of the system, the combined top rate is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

2.1 Rates and residence

A company is resident in Guyana if it is incorporated in Guyana or centrally managed and controlled there. Resident companies are taxed on worldwide income; non-resident companies are taxed only on income derived from Guyana, typically through a branch or agency. The current corporate tax rates are: telephone companies 45%; commercial companies 40%; other (non-commercial) companies 25%; and small businesses engaged in manufacturing and construction services that are registered with the Small Business Bureau 25%. A company deriving income from both commercial and non-commercial activities is taxed at 25%/40% on the respective portions of its profits. A commercial company is defined as one deriving at least 75% of its gross income from the sale of goods it did not manufacture, or one engaged in telecommunications, banking or insurance (other than long-term insurance).

Commercial companies (other than insurance companies) are subject to tax at the higher of 40% of chargeable profits or a Minimum Corporation Tax (MCT) of 2% of turnover. Any excess of MCT over the tax computed at the normal rate is carried forward and set off against corporate tax in future years, subject to the floor that tax payable in any year may not be reduced below 2% of that year's turnover.

2.2 Dividends and participation exemption

Guyana operates a classical system without a formal participation exemption. Dividends paid by a resident company are subject to withholding tax when paid to non-residents; dividends between resident companies are generally taxable but relief from economic double taxation is limited compared to jurisdictions with a full exemption system. Groups commonly manage cascading taxation through capital structuring and by timing distributions, since there is no consolidated group relief for dividend flows. Capital gains on the disposal of shares in a Guyanese company are within the scope of capital gains tax (see 2.3).

2.3 Income determination and deductions

Taxable profit is computed from financial statements prepared under generally accepted accounting principles, adjusted for tax rules. Ordinary business expenses wholly and exclusively incurred in earning income are deductible; capital expenditure is instead relieved through wear-and-tear (capital) allowances under the Income Tax (In Aid of Industry) Act, with initial and annual allowances varying by asset class (typically 5%–50% depending on asset type, with higher rates for plant used in agriculture, manufacturing and mining). Capital gains tax is imposed at a flat 20% on the net chargeable gains derived from the disposal of capital assets held for more than 12 months (gains on assets held for a shorter period, and trading gains, are taxed as ordinary income). Losses on revenue account are deductible; losses on capital account are only relievable against capital gains.

2.4 Interest limitation

Guyana does not operate an EU-style fixed-ratio (EBITDA) interest limitation rule. Interest deductibility instead turns on general 'wholly and exclusively' principles and thin-capitalisation-style scrutiny by the Guyana Revenue Authority of related-party debt where gearing is considered excessive or the interest rate is not at arm's length; excessive or non-arm's-length interest may be disallowed or recharacterised. Withholding tax applies to interest paid to non-residents (see section 4), which in practice constrains aggressive related-party debt funding from abroad.

2.5 Losses

Trading losses may generally be carried forward against future business profits, subject to an annual restriction limiting the loss offset in any year to a proportion of that year's chargeable profits (broadly analogous to a partial-offset cap used to protect the revenue base), with unused losses continuing to carry forward. There is no loss carryback. Losses are attached to the company that incurred them; on a change of ownership without continuity of the loss-making trade, the Commissioner-General may restrict carryforward.

2.6 Group taxation

Guyana has no formal fiscal-unity or group-relief regime; each company is assessed separately and losses cannot be surrendered between group members. Groups operating multiple Guyanese entities must therefore manage profitability and loss positions entity-by-entity, commonly through intra-group service and financing arrangements priced on an arm's-length basis. Mergers and internal reorganisations do not benefit from a statutory rollover regime, so asset transfers between group companies can trigger capital gains tax and stamp duty unless specific relief is negotiated or otherwise available.

2.7 Controlled foreign companies

Guyana does not operate a controlled foreign company (CFC) regime. Resident companies are, however, taxed on worldwide income, so profits of foreign branches (as opposed to foreign subsidiaries) are directly includible. Undistributed profits of foreign subsidiaries are not attributed to Guyanese parents under current law, though the Guyana Revenue Authority continues to strengthen international information exchange and beneficial-ownership transparency, increasing practical scrutiny of offshore holding structures.

2.8 Transfer pricing

Transfer pricing in Guyana is governed by general anti-avoidance and arm's-length principles in the Income Tax Act and Corporation Tax Act rather than a detailed codified transfer-pricing code; the Guyana Revenue Authority increasingly references OECD-aligned arm's-length concepts in practice, particularly for related-party financing, management fees and intra-group services connected with the petroleum and extractive sectors. Formal contemporaneous documentation requirements are less prescriptive than in OECD member states, but taxpayers with related-party cross-border dealings should maintain arm's-length analysis to support deductions and pricing under audit.

2.9 Incentives

Guyana offers tax holidays and duty concessions under the Income Tax (In Aid of Industry) Act and investment-promotion policy administered together with GO-Invest, targeted at manufacturing, agro-processing, non-traditional agriculture, information and communication technology, tourism, and investment outside Georgetown (particularly in Regions other than Region 4). Reliefs include tax holidays of typically up to five to ten years for qualifying new economic activity in priority sectors and regions, accelerated capital allowances, and duty-free importation of plant, machinery and raw materials for approved projects. Small businesses in manufacturing and construction registered with the Small Business Bureau benefit from the reduced 25% rate and additional tax credits for employment creation and new investment.

2.10 Pillar Two

Guyana has not implemented Pillar Two model rules (income inclusion rule, undertaxed profits rule or a qualified domestic minimum top-up tax) and is not a committed member of the OECD/G20 Inclusive Framework's minimum-tax implementation timeline in the way many larger economies are. Large multinational groups operating in Guyana — including in the petroleum sector — should nonetheless monitor exposure to top-up taxation in parent jurisdictions that have implemented an income inclusion rule or undertaxed profits rule, since low-taxed non-commercial-rate Guyanese profits could attract top-up tax offshore even though no domestic minimum tax applies in Guyana itself.

2.11 Branch income and reorganisations

A branch of a foreign company is taxed at the same corporate tax rates applicable to a Guyanese company carrying on the equivalent commercial or non-commercial activity (40% or 25%, as applicable), computed on profits attributable to the branch. Guyana does impose a branch remittance tax: under section 39(7) of the Income Tax Act, Cap. 81:01, an office, branch or agency of a non-resident company that remits or is deemed to remit Guyana-source profits must account for withholding tax on those profits as if the remittance were a distribution, at the 20% rate set by Part 1 of the Third Schedule. The charge falls on profits after corporation tax (section 39(9)), and section 39(8) deems all such profits remitted except to the extent they have been reinvested in Guyana to the satisfaction of the Commissioner-General, disregarding reinvestment in the replacement of fixed assets or in securities held for less than thirteen months, so the tax arises whether or not funds actually leave the country. The rate may be reduced by ministerial direction under section 39(10) or under an applicable double taxation agreement. Domestic reorganisations (mergers, amalgamations and reconstructions) are not automatically tax-neutral; asset transfers between commonly controlled entities can give rise to capital gains tax and stamp duty absent specific ministerial or statutory relief, so restructurings are typically planned around share transactions where possible to manage transaction-tax exposure.

3.1 Residence and rates

Individuals resident in Guyana are taxed on worldwide income; non-residents are taxed on Guyana-source income only. Residence generally follows physical presence (183 days or more in the tax year) or a settled Guyanese home. Personal income tax is charged at a low flat headline structure by regional standards: a threshold-based personal allowance shelters a base amount of employment income from tax, with income above the threshold taxed at 25%, and income above a higher second threshold taxed at 35%. The personal allowance and thresholds are periodically increased in the national budget to keep pace with wage growth and inflation.

3.2 Capital income and real estate

Guyana does not levy a general tax on dividends, interest or capital gains received by resident individuals outside the corporate withholding-tax and capital-gains-tax framework described in section 2.3 — capital gains tax at 20% applies to gains on disposal of capital assets (including real property and unlisted shares) held for more than 12 months, whether realised by companies or individuals. Rental income earned by individuals is assessed as ordinary income at the progressive rates in section 3.1, net of allowable expenses including mortgage interest, repairs and a wear-and-tear allowance on the building. There is no separate net wealth tax.

3.3 Social security and payroll

Employees and employers contribute to the National Insurance Scheme (NIS), with employees contributing approximately 5.6% of insurable earnings and employers approximately 8.4%, subject to an insurable earnings ceiling reviewed periodically. Employers withhold Pay-As-You-Earn (PAYE) income tax monthly from employee salaries and remit both PAYE and NIS contributions to the Guyana Revenue Authority and National Insurance Scheme respectively. A small annual NIS-linked health and old-age benefit structure underpins the contribution design, and self-employed individuals contribute at a blended rate on assessed earnings.

3.4 Inbound individuals

Guyana does not levy inheritance, estate or gift tax, nor a net wealth tax. Expatriate employees are generally taxed on Guyana-source employment income under the same PAYE rules as residents once physically present and working in Guyana, with treaty relief available only in the limited number of jurisdictions with which Guyana has a double tax treaty (principally CARICOM member states and a small number of others). Work permits and immigration approvals are typically required in parallel with payroll registration for inbound assignees, and professional services firms commonly assist with the interaction between CARICOM double-taxation arrangements and Guyanese domestic law for regional secondments.

Guyana imposes withholding tax on specified payments to non-residents, generally at a standard domestic rate before any treaty relief. Dividends, interest, royalties, management fees and other specified payments (including rent and payments for services) made to non-residents are subject to withholding tax, generally at 20%, unless reduced under a double taxation agreement. Guyana's treaty network is limited, centred on the CARICOM Double Taxation Agreement among Caribbean Community member states, together with a small number of bilateral treaties (including with Canada and the United Kingdom); most cross-border payments to non-treaty jurisdictions therefore bear the full domestic withholding rate.

Relief under the CARICOM Double Taxation Agreement generally requires the recipient to be a resident of a CARICOM member state and to provide residence certification to the Guyanese payer, who withholds at the reduced treaty rate at source or, in some cases, the recipient claims a refund. Because Guyana's treaty network is narrow, careful structuring of cross-border financing and licensing arrangements is important to avoid an unrelieved 20% withholding drag on outbound payments to non-treaty jurisdictions, including major petroleum-sector service providers.

5.1 General anti-abuse and hybrids

The Income Tax Act and Corporation Tax Act contain general anti-avoidance provisions empowering the Commissioner-General to disregard or recharacterise transactions and arrangements entered into principally to reduce tax liability, and to adjust related-party pricing that is not on arm's-length terms. Guyana does not yet operate a codified hybrid-mismatch regime of the ATAD type; cross-border hybrid financing and entity mismatches are instead addressed, where relevant, through the general anti-avoidance rule and through withholding tax characterisation of payments as interest, royalties or distributions.

5.2 Exit taxation and disclosure

Guyana does not impose a formal corporate exit tax on migration of residence or transfer of assets offshore, though a transfer of Guyanese assets (including shares in Guyanese companies) by a departing resident may crystallise capital gains tax at 20% under the ordinary disposal rules. There is no DAC6-style mandatory disclosure regime or public country-by-country reporting requirement under domestic law, though Guyana participates in international tax transparency initiatives and information-exchange arrangements coordinated regionally and through the Caribbean Financial Action Task Force framework, and beneficial-ownership registration requirements have been strengthened as part of anti-money-laundering reforms linked to the growing petroleum economy.

6.1 VAT

Value-added tax is levied at a standard rate of 14% on the supply of most goods and services and on imports, with a zero rate applying to exports and a defined list of zero-rated essential goods, and exemptions for specified financial services, residential rental, medical and educational supplies. Registration is compulsory for businesses whose taxable turnover exceeds the statutory threshold (GYD 15 million per annum), with voluntary registration available below that threshold. VAT-registered businesses file monthly returns and remit net VAT payable to the Guyana Revenue Authority by the specified due date each month, with input tax credited against output tax subject to the normal restrictions on non-business and blocked expenditure (such as passenger motor vehicles and entertainment).

6.2 Transaction, payroll and other taxes

Stamp duty applies to a range of legal instruments, including conveyances of real property, share transfers, leases and certain agreements, at rates that vary by instrument and transaction value. Property tax is levied annually on the net property of resident individuals and companies above a specified threshold, at modest progressive rates. Excise tax applies to specified goods, notably petroleum products, alcohol, tobacco and motor vehicles, at rates that vary significantly by category and, for vehicles, by engine size and age. There is no net wealth tax separate from the property tax, and no general payroll tax beyond National Insurance Scheme contributions described in section 3.3. Environmental and depletion levies apply within the petroleum production-sharing framework outside the general corporate tax code.

7.1 Filing, assessment and audit

The tax year is the calendar year, though companies may seek approval to adopt a different accounting year-end with tax computed by reference to the year in which that accounting period ends. Corporate income tax returns are filed annually with the Guyana Revenue Authority, generally within four months of the company's financial year-end, supported by advance/estimated tax payments made in quarterly instalments during the year based on the prior year's liability, with a balancing payment on filing. The Guyana Revenue Authority conducts risk-based audits and desk reviews, with heightened scrutiny of related-party transactions, petroleum-sector contractors and cross-border payments attracting withholding tax. The general assessment and record-retention period is six years, extendable in cases of fraud or wilful default.

7.2 Rulings, appeals and penalties

Taxpayers may object to an assessment by the Commissioner-General within the statutory objection period, with further appeal to the Tax Appeal Court and ultimately to the Court of Appeal on questions of law. Guyana does not operate a formal advance-ruling regime comparable to those in OECD member states, though taxpayers may seek administrative guidance from the Guyana Revenue Authority on the application of specific provisions. Interest and penalties apply to late payment and late filing, and to underpayments identified on audit, with more severe penalties, and potential criminal sanctions, for fraud or wilful evasion; voluntary disclosure ahead of an audit notice is treated as a mitigating factor in penalty determinations.

Late filing and late payment both attract statutory interest and penalties calculated from the original due date, and the Guyana Revenue Authority has been progressively expanding electronic filing and payment channels to reduce compliance friction as petroleum-driven administrative capacity has grown. Taxpayers with a non-calendar accounting year should track filing deadlines from their approved year-end rather than the calendar year.

9.1 Entity choice

The private limited liability company is the standard vehicle for inbound investment, incorporated under the Companies Act with straightforward directors' and shareholders' requirements and no minimum share capital requirement for most activities. External (foreign) companies may instead register a branch, which is taxed on attributable Guyanese profits at the same rates as a domestic company of the equivalent commercial or non-commercial character, and additionally bears the 20% branch remittance tax on profits it is deemed to remit, as described in section 2.11. Petroleum and large extractive-sector investors typically operate through special-purpose Guyanese subsidiaries under production-sharing agreements negotiated with government, which sit outside the general corporate tax code described in this handbook. Partnerships and sole proprietorships are transparent for tax purposes and common for smaller domestic trading and services businesses.

9.2 Structuring and incentives

Investors should classify activities carefully as commercial or non-commercial at the outset, since the rate differential (40% versus 25%) is material and turns on the 75% sourced-goods test or the specified-sector definition described in section 2.1. Manufacturing, agro-processing and regional (outside Georgetown) investment should be evaluated against Income Tax (In Aid of Industry) Act tax holidays and GO-Invest incentive packages, which can materially reduce the effective rate during the holiday period. Because there is no group relief and no formal transfer-pricing safe harbour, related-party financing, management fees and service charges should be documented on an arm's-length basis to withstand Guyana Revenue Authority scrutiny, particularly for groups also operating in the petroleum supply chain where related-party dealings attract close attention.

9.3 Worked effective-rate illustration

A Guyanese non-commercial (manufacturing) company earns EBITDA of GYD 200,000,000, books capital allowances of GYD 30,000,000 and net interest expense of GYD 10,000,000, all on arm's-length terms. Taxable profit is 200,000,000 − 30,000,000 − 10,000,000 = GYD 160,000,000. Corporate tax at the non-commercial rate of 25% is GYD 40,000,000. Turnover for the year is GYD 500,000,000, so the 2% Minimum Corporation Tax (applicable only to commercial companies) does not apply to this non-commercial entity, and the full 25% liability of GYD 40,000,000 stands, an effective rate of 40,000,000 / 160,000,000 = 25.0% on taxable profit. Had the same company instead been classified as commercial with identical figures, tax at 40% would be GYD 64,000,000 against a 2% MCT floor of 500,000,000 × 2% = GYD 10,000,000 — since 64,000,000 exceeds the MCT floor, the company would pay the higher figure of GYD 64,000,000, an effective rate of 64,000,000 / 160,000,000 = 40.0%, illustrating the material impact of the commercial/non-commercial classification.

9.4 Compliance

Expect annual corporate and payroll registration with the Guyana Revenue Authority, quarterly advance tax instalments, monthly PAYE, NIS and VAT compliance, and annual filing of audited or management financial statements supporting the corporate tax return. Groups with cross-border related-party transactions should maintain arm's-length pricing support given the absence of formal transfer-pricing documentation safe harbours, and petroleum-sector contractors should separately track production-sharing-agreement obligations that sit outside the general corporate tax code. Businesses relying on Income Tax (In Aid of Industry) Act incentives should retain GO-Invest approval documentation to support tax-holiday and duty-concession claims under audit.