Trinidad and Tobago: local rules

Trinidad and Tobago has no transfer pricing law and no arm's length rule for related-party pricing. The nearest rule is Income Tax Act, Chap. 75:01, s. 67(1), which applies to corporation tax through Corporation Tax Act, Chap. 75:02, s. 19. It lets the Board of Inland Revenue disregard a transaction that it thinks is artificial or fictitious and reduces tax. The Act uses 'arm's length' only for capital gains rules (such as Rule 4(2) and Rule 17 of the Income Tax Act's gains rules) and 'open market' for director benefits. The government has promised a transfer pricing law in budgets for years. The Budget Statement of October 2026 says a draft national policy framework is done, the OECD has been asked to review it, and the policy and its primary legislation are a priority this fiscal year. No bill has been found, so nothing is in force.

There are no transfer pricing documentation rules, no master file or local file, and no transfer pricing form. Companies must keep books and records, and the Board has general powers to ask for information and inspect records (Income Tax Act ss. 117 and 118). Country-by-Country reporting is the only transfer pricing style filing, and it is in a separate Act. The government says future rules will follow the OECD, but no bill has been published.

No transfer pricing methods are prescribed. Nothing in the statutes points to the OECD Guidelines. The only pricing-style tests are the artificial or fictitious test in Income Tax Act s. 67(1) and market value rules in the capital gains rules.

There are no transfer pricing penalties. An adjustment under s. 67 is a normal assessment. A company that files late (after six months) pays TTD 1,000 for every six months or part of six months (Corporation Tax Act s. 19A, which the Board may waive or reduce). Tax paid late or short carries interest of 20% a year (Income Tax Act s. 103). Failing to file a return is also an offence (Income Tax Act s. 76(5)). Country-by-Country failures: an administrative fine of up to TTD 20,000, or on conviction a fine of TTD 250,000 and up to 10 years in prison (CbC Act s. 20). A knowingly false report carries TTD 500,000 and up to 10 years (s. 15). The IRD says it does not apply penalties for late CbC notifications, and no regulations setting the administrative fine were found.

Nothing is enacted. No Pillar Two law (income inclusion rule, undertaxed profits rule or domestic minimum top-up tax) was found in the Income Tax Act, the Corporation Tax Act, the Budget Statement of October 2026 or any other official source. There is no Pillar Two filing deadline.

Corporation tax return: due 30 April after the calendar year of income, for every company, whatever its year end (Income Tax Act ss. 2 and 76(1)). The tax year is the calendar year, and a company is taxed on the accounting period that ends in that year (Corporation Tax Act s. 5(1)). Tax is paid in four instalments on 31 March, 30 June, 30 September and 31 December of the year of income, with the balance on 30 April (s. 79(1)). Under Interpretation Act, Chap. 3:01, s. 25(4), a deadline on a Saturday, Sunday or public holiday moves to the next day that is none of these. Country-by-Country reporting: Act No. 2 of 2024 came into force on 20 December 2024 (Proclamation, Legal Notice No. 231 of 2024), so it first applies to fiscal years starting on or after that day. The threshold is USD 850m, the notification is due by the last day of the reporting fiscal year, and the report is due 12 months after it. Board guidelines (Gazette, 3 January 2025) suspend local filing by Trinidad and Tobago subsidiaries of foreign groups until further notice, so only a resident ultimate or surrogate parent files the report.