Bahamas

Personal income tax

No.

Corporate income tax

Yes (Annual Business Licence Tax for Companies carrying on business in the Bahamas).

Exchange restrictions

Resident: Some.

Substance requirements brief summary

Substance requirements are stipulated by the Commercial Entities (Substance Requirements) Act, 2018 (the “Act”) which applies to IBCs engaged in any of the following “relevant activities” in The Bahamas:

a. banking business; b. insurance business; c. fund management business; d. financing and leasing business; e. headquarters business; f. distribution and service centres business; g. shipping business; h. intellectual property asset activities; or i. a holding company engaged (directly or via subsidiary) in one of the activities listed above.

An IBC falling within any of these categories is an “included entity” under the Act and must:

1. have a substantial economic presence in The Bahamas; and 2. report to the Minister of Finance on its compliance with the Act. An IBC not engaged in a relevant activity (either directly or via subsidiary) is considered a passive holding entity and is not required to comply with the substance requirements of the Act, save that strategic decisions concerning the IBC must be made in The Bahamas.

Treaties as of 17/09/2013

1. Czech Republic TIEA – Signed- 6th March, 2014 Date of Entry into Force (DEIF)- 2nd April, 2015 2. Georgia TIEA- Signed- 4th November, 2016 DEIF- 1st September, 2017 3. Indonesia TIEA- Signed- 25th June, 2015 DEIF- not yet in force 4. Ireland TIEA- Signed- 12th January, 2015 DEIF- 19th February, 2016.

DEIFS

1. The TEIA with the US would’ve entered into force on the 31st of December, 2003. 2. The TEIA with Belgium came into force on the 11th February, 2014. 3. The TEIA with Greenland came into force on the 21st June, 2012. 4. The TEIA with Iceland came into force on the 15th October, 2012. 5. The TEIA with Australia came into force on the 11th January, 2011.

Double Tax Treaties

Being that The Bahamas does not levy direct taxes, there are presently no double tax treaties between The Bahamas and any other jurisdiction.

Permitted Currencies

No restrictions. B$1=US$1.

Minimum authorised capital

No minimum capital required.

Minimum share issue

None. (in practice, one).

Shelf companies

No.

Timescale for new entities

Two working days with new RGD eServices.

Incorporation Fees

Non-Resident Capital: not exceeding $50,000:  B$2,052.20 (US$2,063.00) Capital exceeding $50,000:  B$2,852.20 (US$2,867.00) Resident (prices are VAT inclusive): Capital not exceeding $50,000:  B$2,220.20 (US$2,232.00) Capital exceeding $50,000:  B$3,020.20 (US$3,036.00) If express service/ incorporation is needed, the Registrar will issue the Certificate of Incorporation within 1 business day at an extra cost of US$450 in addition to the incorporation fee stated payable to the Registrar.

Annual fees

For IBCs, the fee payable is BS$350 where the authorised capital is not over BS$50,000 and BS$1,000 where the share capital is over BS$50,000.

Minimum number

One.

Residency Requirements

Generally, a director/ Secretary need not be resident. However, residency requirements may be stipulated by the Commercial Entities (Substance Requirements) Act, 2018. (See Substance Requirements note below.)

Corporate Directors

Yes.

Meetings/ Frequency

Discretionary.

Disclosure

Register of directors and officers. Disclosure of Beneficial Ownership may be stipulated by The Register of Beneficial Ownership Act, 2018.

Bearer shares

Not allowed.

Minimum number

Minimum of one shareholder.

Public share registry

No.

Meetings/ Frequency

AGMs are not required and can be held anywhere or by telephone.

Annual return

No.

Audit requirements

None, unless required by the IBC's Articles of Association, but company required to ensure that reliable accounting records are kept as required by the IBC Act.

Registered office

Yes.

Registered Agent

Yes.

Domicile issues

Change of domicile permitted.

Company naming restrictions

IBC Prohibited Names: 'assurance', 'bank', 'building society', 'chamber of commerce', 'chartered', 'cooperative', 'imperial', 'municipal', 'royal', 'trust', etc. Names must end with an appropriate suffix such as 'incorporated', 'limited', 'corporation', 'gesellschaft mit beschrankkter haftung', 'sociedad anonim' or respective abbreviations.