Revised Laws of Saint Lucia (2022)

10.   Income deemed to have accrued from sources whether in or outside Saint Lucia

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    (1)   Income accrued to a person accrues from a source situated whether in or outside Saint Lucia where it accrues to that person in respect of—

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      (a)     any employment exercised whether in or outside Saint Lucia irrespective of where payment is made or the contract of employment is entered into;

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      (b)     any employment exercised out of Saint Lucia—

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        (i)     in the performance of duties on behalf of the Government, or

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        (ii)     as an officer or member of the crew of a ship or aircraft engaged in international traffic, by such person being an individual who is ordinarily resident whether in or outside Saint Lucia;

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      (c)     interest from any person being—

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        (i)     an individual who is ordinarily resident whether in or outside Saint Lucia, where the indebtedness—

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          (A)     was incurred in connection with the acquisition of, or

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          (B)     was charged against, any property situated in or to be brought into Saint Lucia, or

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        (ii)     any other person, whether resident or non-resident, who has a permanent establishment whether in or outside Saint Lucia in connection with which the indebtedness on which the interest accrued was incurred, where such interest is borne by such permanent establishment;

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      (d)     any property physically situate whether in or outside Saint Lucia;

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      (e)     the provision of management services, including personal services and technical and managerial skills, whether in or outside Saint Lucia where such services are provided for the purposes of a business carried on whether in or outside Saint Lucia and the cost of such services is borne by that business, irrespective of where the contract for such services was entered into; (Amended by Act 12 of 2018)

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      (f)     a source of income which under any international agreement made under section 60, is considered to be situated whether in or outside Saint Lucia; (Amended by Act 12 of 2018)

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      (g)     income from carrying on a business whether in or outside Saint Lucia. (Inserted by Act 12 of 2018)

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    (2)   Where, under this Act, or under any international agreement made under section 60, income is considered to accrue—

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      (a)     to a person;

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      (b)     from a source; or

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      (c)     in a year of income,

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    a reference to income accrued shall be construed as including income considered to accrue.

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    (3)   Income that is not deemed to have accrued from a source out of Saint Lucia in accordance with section 10A shall be deemed to have accrued from a source whether in or outside Saint Lucia. (Inserted by Act 12 of 2018)