Group tax filing is not allowed in Saint Lucia; however, group tax relief is available under certain circumstances to allow the trading losses, excluding the current loss, of a resident company within a group to offset the profits of another resident company within the same group. A claim for group relief requires the consent of the Comptroller of the IRD and is only available to resident companies.
Related-party transactions are accepted if they are made on an arm’s-length basis. The IRD has the power under the Income Tax Act to make any adjustment deemed necessary to place such transactions at arm’s length.
No provision exists for thin capitalisation in Saint Lucia.
Controlled foreign companies (CFCs)
There are no provisions relevant to CFCs in Saint Lucia.