Foreign Currency Permits for companies that earn 100% of their annual income in foreign currency including former IBC's and ISRLs

The following will be needed to apply for an FCP:

• Details of the registered office, where applicable;
• Details of the service provider, where applicable;
• Details of the auditor;
• Date of the end of the financial year;
• The number of persons to be employed who require work permits;
• The positions to be held by the persons who require work permits;
• The names, addresses and company numbers of every related entity carrying on business that is licensed, incorporated, registered or organized in Barbados;
• A list of the activities in which the qualified person will engage and a full description of the business that it intends to carry on;
• The academic qualifications, training, experience, corporate status and description of the business of every director and manager, where applicable;

The new legislation does not define economic substance in the context of Barbados law, but the term generally is understood under international standards as relating to guidelines developed to prevent tax avoidance, under which a transaction is required to have a substantial purpose aside from taxation purposes to be considered valid. Provisions for the imposition of an economic substance test for companies carrying on business in Barbados became effective on 1 January 2019. The Director of International Business has not yet issued guidance or a practice direction regarding the application of the test.

A company engaged in relevant business activities must carry out its “core-income generating activities” (COGA) within Barbados to fulfill the economic substance test which is applicable to resident companies carrying on business in Barbados that are engaged in “relevant business activities,” which include the following:

• Banking business;
• Insurance business;
• Finance and leasing business;
• Fund management business;
• Headquarters business;
• Holding company business;
• Intellectual property holding business;
• Shipping business;
• Distribution and service center business; and
• Such other activities as the Minister of International Business may prescribe by order to be relevant activities.