The CCJ Upholds Imposition of Withholding Tax on Payments by Branch to Foreign Head Office 

On Tuesday, 4 November 2025, the Caribbean Court of Justice (CCJ) delivered judgment in Bank of Nova Scotia v Comptroller of Inland Revenue [2025] CCJ 13 (AJ) LC. The Court dismissed the appeal by the Bank of Nova Scotia (‘BNS’) and agreed with the Court of Appeal of the Eastern Caribbean Supreme Court (Saint Lucia) that payments by BNS Saint Lucia to related foreign associates were subject to withholding tax.

Access the full media release here: Media release 32_2025

Access the judgment here: 2025_CCJ_13_AJ_LC