Key Takeaways
- TIEAs enable tax information exchange between Grenada and partner jurisdictions but, unlike double tax treaties, provide no relief from double taxation.
- Exchange-of-information requests follow a defined process, and the data shared is limited by the scope set in each agreement.
- Confidentiality safeguards restrict how exchanged information can be disclosed and used by requesting authorities.
- Grenada's TIEA commitments align with OECD transparency and Global Forum standards, shaping the outlook for non-resident owners.
What TIEAs Mean for Grenada and Its Foreign-Owned Companies
Tax Information Exchange Agreements (TIEAs) in Grenada are bilateral instruments that let foreign tax authorities request account and tax data on residents of their own country who hold interests on the island. Grenada has signed several such agreements and operates them through its Inland Revenue Division (IRD), the competent authority for international exchange, in line with the OECD transparency standard.
This matters to any non-resident who owns a Grenadian company or holds a financial account there, because the information your home revenue authority can obtain depends in part on these treaties. The sections below explain how TIEAs differ from double tax treaties, who Grenada's partners are, what data is covered, how a request works, and what it all means for a foreign owner.
The topic is most relevant to foreign business owners, investors, and their advisers weighing transparency exposure before incorporating or maintaining an entity on the island.
How a TIEA Differs from a Double Tax Treaty: Exchange Without Relief
A TIEA does one thing: it opens a channel for tax authorities to share information. It contains no rules on which country may tax which income, so it offers no relief from double taxation.
A comprehensive double tax agreement, by contrast, allocates taxing rights and prevents the same income being taxed twice. The aim of a TIEA is narrower, namely to support the administration of each party's domestic tax laws and to deter offshore evasion and fraud.
Grenada maintains at least one full Double Taxation Convention, with the United Kingdom, ensuring income earned in one country is not taxed again in the other. Its TIEAs with other partners provide information sharing alone, not that kind of relief.
A TIEA governs the flow of tax information; a double tax treaty governs which country gets to tax income. Holding one does not give you the benefit of the other.
Each TIEA implements the OECD's Exchange of Information on Request (EOIR) standard, meaning partners share data only when they ask for it. Information can still move between countries through a TIEA even where no double tax treaty or FATCA arrangement exists.
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Grenada's TIEA Network: How Many Agreements and With Which Partners
Cross-referencing partner-country treaty lists shows Grenada named as a TIEA partner of a substantial group of economies. A single consolidated table with exact signature and entry-into-force dates is not published by the IRD in its public pages, so the list below is drawn from partner-side records.
| Region | Partners |
|---|---|
| Nordic group | Iceland, Norway, Sweden, Denmark, Finland, Faroe Islands, Greenland |
| Other OECD | Australia, Canada, France, Germany, Ireland, Netherlands, New Zealand, United Kingdom |
| Caribbean | Barbados, Belize, Dominica, Guyana, Jamaica, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Trinidad and Tobago |
The clearest documented example is the agreement with Canada, signed on 19 July 2017 and in force from 21 June 2018. You can read the Canada–Grenada TIEA in full on the Canadian finance ministry site.
The United States is a notable absence from this list. Grenada does not appear on the US Treasury TIEA list because the two countries exchange data under a FATCA intergovernmental agreement instead, signed in 2016.
The Legal Basis: Domestic Law Enabling Information Exchange in Grenada
The IRD, a division within the Ministry of Finance, administers inland revenue laws and acts as the competent authority for international exchange. When a partner submits a request, it is the IRD that gathers and supplies the information.
The agreement with Canada covers all taxes imposed or administered by the government, which ties the exchange obligation to the country's domestic tax base. For a foreign owner, that means data tied to your local tax affairs can be the subject of an inbound request.
A TIEA also requires each party to have legal and administrative frameworks that support exchange, and exchange cannot be blocked by bank secrecy. The specific enabling statute and section in domestic legislation were not retrievable from the public pages reviewed; foreign owners who need that detail should confirm it directly with the IRD.
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Scope of Information Covered Under Grenada's TIEAs
Under a TIEA, the competent authorities exchange information that is "foreseeably relevant" to applying their tax laws. That reaches the determination, assessment, and collection of taxes, the recovery of tax claims, and the investigation or prosecution of tax matters, covering both civil and criminal cases.
A few features widen this scope in ways a non-resident should understand:
- Information is supplied even where the conduct under investigation would not be a crime under Grenadian law.
- If the IRD does not already hold the requested data, it must use its information-gathering powers to obtain it, even when it has no domestic need for that information.
- Bank secrecy cannot be used to refuse a request.
Parallel frameworks broaden what is reported. Under the Common Reporting Standard, shared data includes the taxpayer's name, tax identification number, date and place of birth, and financial account details; under the FATCA agreement, the data exchanged on each US reportable account is set out in the agreement text.
How an Exchange-of-Information Request Works in Practice
A partner authority submits a written request, usually following the OECD Model Template, and the IRD responds by gathering and supplying the relevant information. Exchange happens on request only, not automatically or spontaneously, unless a protocol extending the scope has been adopted.
In practice, very little has happened yet. Grenada's 2024 OECD peer review records that the country does not have enough EOIR experience for its practices to be meaningfully assessed, indicating that few requests, if any, have been processed.
No published processing times, fees, or formal administrative procedure for a requesting partner appear on the IRD portal. A partner authority or adviser seeking that detail should approach the IRD directly.
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Confidentiality Safeguards and Limits on Disclosure
Information exchanged under a Grenadian TIEA is confidential and may be used only for the purposes for which it was provided. It can appear in public court proceedings or judicial decisions, but it may not be passed to any other person, authority, or jurisdiction.
There is one controlled exception: where Grenada gives prior written consent, the information may be used for purposes permitted under a mutual legal assistance treaty in force between the parties. The confidentiality rules sit in the agreement's confidentiality article, which in the Canada agreement is Article 8.
Safeguards work in both directions. Each party must ensure that the protections its laws grant to taxpayers are not applied to unduly block or delay exchange, and the peer review process is designed to flag secrecy laws that would frustrate cooperation.
TIEAs and the OECD Transparency and Global Forum Standards
The Global Forum on Transparency and Exchange of Information for Tax Purposes reviews jurisdictions against the EOIR standard and rates them across four tiers: Compliant, Largely Compliant, Partially Compliant, and Non-Compliant. Across the second round, 132 jurisdictions have been fully reviewed and 91% received a satisfactory rating.
Grenada's position is at an early stage. Its November 2024 Second Round review covered only Phase 1, the legal and regulatory framework, which was found sufficient to proceed to Phase 2, the assessment of practice, due no later than 2027.
| Element | Status |
|---|---|
| Phase 1 (legal framework) | Assessed, sufficient to advance |
| Phase 2 (practice) | Scheduled by 2027 |
| Overall compliance rating | Not yet assigned (follows Phase 2) |
| CRS / automatic exchange | Reporting since 2018 |
| FATCA agreement with US | Signed 2016 |
No overall compliance rating has been issued, because that follows Phase 2. Alongside the request-based TIEA channel, the automatic exchange layer under CRS has been operational since 2018.
What TIEAs Mean in Practice for a Non-Resident Owner
For most foreign owners, the realistic exposure runs through automatic channels rather than TIEA requests. Account data you hold on the island can reach your home revenue authority through CRS for most OECD and G20 countries, or through a bilateral TIEA request where that route applies.
US persons face a separate channel. Under FATCA, financial institutions on the island report US account holders to the IRS, and Grenada shares information on accounts and assets exceeding $50,000; failure to file FBAR and FATCA reporting at home can trigger IRS offshore penalties.
A TIEA changes only the flow of information, not who may tax what. Non-residents remain taxable on Grenadian-sourced income, such as locally generated business profits, and a treaty does not alter that.
Information about your account can reach your home tax authority whether or not you disclose it. Treat foreign income reporting in your country of residence as the controlling obligation.
The request-based risk is lower than in jurisdictions with a long exchange record, given the limited EOIR experience noted in the 2024 review. That gap narrows once Phase 2 begins and practice is assessed.
Outlook: Where Grenada's TIEA Commitments Are Heading
The next milestone is the Phase 2 review of actual exchange practice, scheduled no later than 2027. That assessment will determine the first overall compliance rating.
Two paths could deepen the country's commitments. A 2015 OECD Model Protocol lets jurisdictions extend existing TIEAs to cover automatic or spontaneous exchange, a route the island could use to upgrade its request-only treaties; separately, the CRS automatic layer already operates regardless of whether individual TIEAs are upgraded.
Treaty expansion tends to move slowly. Canada opened negotiations as far back as June 2011, yet the agreement only entered force in 2018, and no new TIEA negotiations or signings have surfaced in public sources after that date. Monitoring the OECD Global Forum and the Canadian finance TIEA pages is the practical way to track any change.
Conclusion
TIEAs in Grenada open a request-based channel for foreign tax authorities while leaving taxing rights untouched, and the country pairs that with operational CRS reporting and a FATCA agreement covering US account holders. The realistic exposure for a non-resident runs through automatic exchange rather than the still-untested request route, but the legal framework is in place and Phase 2 review will sharpen practice by 2027. The sound approach is to report your foreign income correctly at home and treat information sharing as a given. Plan on the assumption that data held on the island can reach your home authority.
How Expanship Can Help Your Business in Grenada
Expanship helps foreign owners understand their exchange-of-information exposure under Grenada's TIEAs, FATCA, and CRS, and structure their affairs so reporting obligations at home are met cleanly. The same team handles the wider set of tasks a foreign-owned entity needs from formation through ongoing compliance.
- Company formation and structuring for non-resident owners
- Registered agent and registered office services
- Tax registration and filing with the Inland Revenue Division
- Ongoing compliance management and annual obligations
- Accounting and bookkeeping support
- Introductions to local banking partners
To discuss your situation, contact Expanship Grenada.
Frequently Asked Questions
No. A TIEA only allows tax authorities to exchange information and contains no rules on taxing rights, so it neither creates nor relieves double taxation. Relief from double taxation comes from a double tax treaty, such as the convention Grenada holds with the United Kingdom.
No. The US does not appear on the Treasury TIEA list because it exchanges data with Grenada under a FATCA intergovernmental agreement signed in 2016. Under that arrangement, financial institutions report US account holders, and accounts and assets above $50,000 are shared with the IRS.
The Inland Revenue Division, part of the Ministry of Finance, is the competent authority for international exchange. It receives requests from treaty partners and uses its powers to gather and supply the relevant data, even where it has no domestic need for that information.
No. A TIEA requires that exchange not be hindered by bank secrecy, and partners must have frameworks that support cooperation. The Global Forum peer review process is designed to identify and press for amendment of any secrecy law that would block exchange.
The practical risk is lower than in jurisdictions with an established track record, because Grenada's 2024 peer review found it lacks sufficient EOIR experience to assess. That said, the legal framework is operational, automatic exchange under CRS has run since 2018, and the request-based gap narrows once the Phase 2 review begins, scheduled by 2027.
CRS exchange is automatic and includes the account holder's name, tax identification number, date and place of birth, and financial account details. A TIEA request, by contrast, is made only when a partner asks and covers information that is foreseeably relevant to applying its tax laws.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
