1. Introduction to the Guyanese Fiscal Framework

The transformation of the Co-operative Republic of Guyana from an agrarian-based economy to a global heavyweight in the energy sector represents one of the most significant economic shifts in the Western Hemisphere during the twenty-first century. This rapid metamorphosis is underpinned by a fiscal architecture that is at once historic and actively evolving. The tax code of Guyana is not a monolithic entity; rather, it is a stratified system of statutes, regulations, and contractual overrides that seeks to balance the traditional revenue needs of a developing nation with the sophisticated demands of international capital, particularly in the hydrocarbon sector.

To understand the current tax environment, one must navigate a legislative history that stretches back to the colonial era, heavily amended by modern exigencies. The foundational document, the Income Tax Act (Chapter 81:01), originally enacted as Act 17 of 1929, has been subject to dozens of amendments—from the post-independence adjustments of the 1960s and 70s to the comprehensive overhauls seen in the Fiscal Enactments (Amendment) Act of 2024 and 2025. This layering of legislation creates a complex compliance environment where colonial-era provisions regarding “wear and tear” coexist with modern digital service tax mechanisms and production sharing agreements (PSAs) that effectively function as independent tax codes for specific multinational entities.

The administration of this complex web falls under the purview of the Guyana Revenue Authority (GRA). Established under the Revenue Authority Act of 1996, the GRA consolidated the functions of the Inland Revenue Department and the Customs and Excise Department into a single semi-autonomous agency. The Commissioner-General of the GRA is vested with broad powers to assess tax, audit records, and enforce collection, a mandate that has become increasingly critical as the volume of cross-border transactions explodes. The Authority is currently in a phase of digitization and modernization, evidenced by the rollout of the “Optimal” e-services platform and the rigorous enforcement of tax compliance certificates for land transfers and tender processes.

This report provides an exhaustive, expert-level examination of the Guyanese tax code as it stands in early 2025. It dissects the statutory obligations for individuals and corporations, distinguishing between the general tax regime and the specialized frameworks for petroleum and mining. Furthermore, it offers a granular analysis of the interplay between Guyanese tax law and the United States Internal Revenue Code (IRC), highlighting the intricate mechanisms of foreign tax credits, the implications of “dual capacity” taxpayer status for oil majors, and the strategic opportunities and risks for expatriate workers and multinational investors.

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2. Individual Taxation: Jurisdictional Scope and Statutory Mechanics

The taxation of individuals in Guyana is predicated on the concept of residency rather than citizenship, a distinction that is paramount for the growing expatriate workforce supporting the oil and gas industry. The Income Tax Act provides the statutory basis for determining liability, defining the scope of chargeable income and the varied allowances that shape the effective tax burden.

2.1 Residency and the Scope of Chargeability

The determination of residency is the threshold issue for all individual taxpayers. Under the Income Tax Act, an individual is deemed a resident of Guyana if they are present in the country for more than 183 days in a calendar year. This “substantial presence” test triggers worldwide tax liability, whereas non-residents are taxed solely on income sourced within Guyana.

Resident Taxpayers:

Residents are subject to tax on income derived from Guyana and on foreign income received in Guyana. This remittance-based taxation for foreign income is a critical nuance; income earned abroad and kept abroad is generally outside the Guyanese tax net for residents who are not domiciled in Guyana, although the definition of “received” can be interpreted broadly to include funds used to settle local debts. For those domiciled and ordinarily resident, worldwide income is theoretically capturing the tax base.

Non-Resident Taxpayers:

Non-residents are taxed strictly on income directly derived from sources within Guyana. This includes emoluments for services performed in Guyana, regardless of where the contract was signed or where the payment is remitted. Crucially, earned income arising outside Guyana to a person not ordinarily resident is taxable only if received in Guyana. This creates a specific planning window for short-term business travelers (under 183 days) who may be subject to different withholding tax regimes compared to the Pay As You Earn (PAYE) system applicable to residents.

2.2 The 2025 Structural Adjustments: Rates and Thresholds

The 2025 National Budget introduced significant amendments to the Income Tax Act designed to alleviate the cost-of-living crisis driven by inflation in the rapidly expanding economy. These changes, effective January 1, 2025, fundamentally altered the progressivity of the tax scale.

The Progressive Rate Structure:

Prior to 2025, individuals faced a dual-rate structure of 28% and 40%. The Income Tax (Amendment) Act No. 2 of 2025 reduced these rates and expanded the bands, providing substantial relief across the income distribution.

Tax Parameter	Pre-2025 Regime	2025 Regime (Current)	Economic Implication
Standard Tax Rate	28%	25%	Immediate increase in disposable income for all taxpayers.
Top Marginal Rate	40%	35%	Enhances competitiveness for attracting senior foreign talent.
Chargeable Income Threshold	GYD 2,400,000 / year	GYD 3,120,000 / year	Expands the lower tax band, delaying the application of the top rate.
Personal Allowance (Free Pay)	Greater of GYD 1.2M or 1/3 Income	Greater of GYD 1.56M or 1/3 Income	Raises the tax-free floor significantly.

The Strategic “One-Third” Allowance:

A unique feature of the Guyanese tax code, preserved and enhanced in 2025, is the variable Personal Allowance. Section 20(1)(a) allows a deduction of the greater of a statutory fixed amount (now GYD 1,560,000) or one-third (1/3) of the individual’s gross income.

This mechanism introduces a regressive benefit structure that favors high-income earners. Unlike standard personal allowances that phase out as income rises, the Guyanese allowance scales indefinitely. For an expatriate oil executive earning GYD 100 million annually, the tax-free allowance is GYD 33.3 million—far exceeding the relief available to a middle-income worker. This structural design acts as a tacit incentive for high-value human capital, effectively capping the average tax rate well below the statutory marginal rates of 25% or 35%.

2.3 The Knowledge Base of Deductions and Allowances

Beyond the statutory personal allowance, the tax code provides a specific menu of deductions aimed at social policy goals, such as home ownership and social security coverage.

2.3.1 National Insurance Scheme (NIS) Contributions

Contributions to the NIS are a mandatory statutory deduction for all employed and self-employed persons. These contributions are deducted before tax, thereby reducing chargeable income.

• Contribution Rate: Employees contribute 5.6% of their insurable earnings.
• Insurable Ceiling: Contributions are capped. As of 2024/2025, the ceiling on insurable earnings is GYD 280,000 per month. Income earned above this threshold does not attract further NIS liability, which effectively slightly reduces the marginal burden on high earners.

2.3.2 Medical and Life Insurance Relief (Section 16)

Section 16 of the Income Tax Act allows taxpayers to deduct premiums paid for medical and life insurance. This provision was enhanced in the 2025 fiscal package to encourage private health coverage.

• Deduction Limit: The deduction is capped at 10% of gross salary or GYD 600,000 annually (raised from GYD 360,000), whichever is lower.
• Mechanism: This is claimed annually on the tax return (Form 2) or adjusted through PAYE if the employer manages the deduction.

2.3.3 Mortgage Interest Relief (MIR)

The MIR program is a significant subsidy for the housing market, administered under Section 20A(1) of the Income Tax Act. It allows resident individuals to deduct the interest paid on mortgage loans from their chargeable income.

• Eligibility: The applicant must be a first-time homeowner occupying the property.
• Loan Ceiling: The relief is applicable to the interest portion of loans up to GYD 30 million. This ceiling was recently doubled from GYD 15 million to accommodate surging real estate prices.
• Process: Taxpayers must obtain a “Letter of Approval” from the GRA and submit it to their lending institution or employer to adjust tax deductions at source, or file for a refund at year-end.

2.3.4 Child Allowance

Reintroduced and adjusted in recent amendments, Section 20(1)(b) provides a deduction for taxpayers with dependent children.

• Allowance: GYD 120,000 per annum for each unmarried child under the age of 18.
• Restriction: This allowance is apportioned based on the number of months worked and can only be claimed by one parent per child, preventing double-dipping by households.

2.3.5 Employment-Related Allowances

The tax treatment of employment benefits is rigorous. The general rule is that all allowances are taxable unless specifically exempted.

• Taxable Allowances: Housing allowances (cash), utility allowances, security allowances, and meal allowances (unless proven to be for specific business purposes) are added to gross income and taxed.
• Exempt Allowances:

• Leave Passage: Allowances paid for travel (vacation) are exempt only if the employee actually travels and provides proof (tickets). If the allowance is paid in cash without travel, it is fully taxable.
• Medical Discharge & Severance: Specific exemptions exist for severance pay and payments related to medical discharge, provided they meet statutory criteria regarding the termination of employment.
• Subsistence/Travel: Allowances for business travel and subsistence are exempt if the Commissioner-General is satisfied they represent actual expenditure incurred in the performance of duties.

2.4 Taxation of Foreign Workers and Expatriates

The regime for foreign workers bifurcates based on the length of stay and the nature of the contract. This area is fraught with compliance risks for multinational employers.

The 183-Day Rule and Treaty Relief:

Foreign workers present for less than 183 days are generally classified as non-residents.

• Withholding Tax (WHT): If classified as independent contractors, they are subject to a 20% WHT on gross payments. This is a final tax, and they do not file a tax return.
• PAYE for Non-Residents: If a non-resident is deemed an employee (a contract of service rather than for service), they are subject to PAYE. Crucially, non-residents are not entitled to the personal allowance (free pay). Therefore, they are taxed on the first dollar earned in Guyana, typically resulting in a higher effective tax rate than residents.

Contractor WHT (Section 10B):

A specific provision, Section 10B of the Corporation Tax Act, imposes a 10% WHT on payments to non-resident companies or individuals for “contract undertakings” (supply of labor or equipment). This often catches foreign consultants and technical service providers. The distinction between the 20% WHT for management/technical fees and the 10% WHT for contract undertakings is a common area of dispute and requires careful contract drafting.

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3. Corporate Taxation: A Dual-Track System

The Guyanese corporate tax code is characterized by a stark dichotomy between “commercial” and “non-commercial” activities. This structural split was designed to incentivize manufacturing and production while capturing higher revenues from the trading and service sectors.

3.1 Corporate Classification and Rate Disparity

The Corporation Tax Act (Chapter 81:03) classifies companies based on the source of their gross income.

Commercial Companies:

Defined as companies deriving at least 75% of gross income from trading in goods not manufactured by them, or from commission agencies, banking, and insurance (excluding long-term insurance).

• Tax Rate: 40%.
• Telecoms: Telecommunication companies face a super-rate of 45%, reflecting the profitability and regulated nature of the sector.

Non-Commercial Companies:

Defined as companies that do not meet the commercial threshold—primarily manufacturers, service providers (outside banking/telecoms), and construction firms.

• Tax Rate: 25% (Reduced from 27.5% in recent years to boost industrial competitiveness).

Dual-Activity Companies:

Companies engaging in both activities must segregate their income. If the commercial component exceeds 75%, the entire income is taxed at the punitive 40% rate. If it is below 75%, the income is apportioned, and the respective rates are applied to the distinct profit streams. This incentivizes diversified conglomerates to carefully manage their revenue mix to avoid the 75% “cliff”.

3.2 The Minimum Corporation Tax (MCT)

To counter base erosion—where companies report minimal profits through aggressive deductions—Guyana enforces a Minimum Corporation Tax.

• Rate: 2% of Turnover (Gross Receipts).
• Applicability: Commercial companies must pay the higher of the standard profit-based tax (40% of chargeable profits) or the MCT (2% of revenue).
• Carry Forward Credit: If a company pays MCT in a given year because it exceeds the profit tax, the excess MCT paid over the hypothetical profit tax can be carried forward. This credit can be used to offset future profit tax liabilities in years where profitability returns, but it cannot reduce the tax payable below the 2% turnover floor for that year.

3.3 Knowledge Base of Corporate Deductions

Corporate taxable income is derived from net profit adjusted for statutory deductions. The general rule allows deductions for expenses “wholly and exclusively” incurred in the production of income.

3.3.1 Capital Allowances (Wear and Tear)

The Income Tax Act and the Income Tax (In Aid of Industry) Act do not recognize accounting depreciation. Instead, a system of Capital Allowances is used.

Initial Allowances:

Granted in the year of acquisition for specific industries. For example, the mining and petroleum sectors often enjoy accelerated initial allowances (e.g., 20% or 40% depending on the specific act or agreement).

Annual Allowances (Wear and Tear):

Calculated on the reducing balance method (or straight line if elected, capped at 90% of cost).

Asset Category	Rate (Reducing Balance)	Strategic Note
Aircraft	33 ⅓%	High rate supports transport logistics in the hinterland.
Boats / Vessels	10%	Relevant for river transport and logistics.
Electronic Office Equipment	50%	Computers and software; rapid write-off incentivizes tech adoption.
Plant & Machinery	20%	Standard rate for industrial equipment.
Motor Vehicles	20%
Buildings (Housing Machinery)	5%	Industrial buildings.
Buildings (Non-Industrial)	2%	Warehouses, offices; very slow write-off.
Green Energy Equipment	100% (over 2 years)	Solar/Wind/Biomass assets can be written off in 2 years (50% per year).

Balancing Allowances and Charges:

When an asset is sold, a “balancing calculation” is performed. If the sale proceeds are less than the tax written-down value, a Balancing Allowance (deduction) is given. If proceeds exceed the value, a Balancing Charge (taxable income) is added, effectively recapturing excess depreciation claimed.

3.3.2 Loss Relief Mechanics

• Carry Forward: Net operating losses can be carried forward indefinitely.
• The 50% Cap: Crucially, losses brought forward cannot reduce the chargeable income of any year by more than 50%. This ensures the Treasury always collects tax on at least half of the current year’s profits, regardless of historical losses.
• Exceptions: The 50% limitation does not apply to companies in the petroleum sector or those enjoying tax holidays.
• No Carry Back: Losses cannot be carried back to recover taxes paid in previous years.

3.3.3 Export and Land Development Allowances

• Export Allowance: A specialized deduction for non-traditional exports. It is calculated as a percentage of export profits, designed to encourage diversification beyond raw commodities.
• Land Development: Expenditure on land clearing and development for agriculture can be amortized, typically allowing 10% of the actual expenditure to be claimed annually.

3.4 Administrative Compliance and Penalties

Filing Deadlines:

Corporate returns (Form 2) are due by April 30th of the following year.

Advance Taxes: Companies are required to pay advance corporate tax in quarterly installments (March 15, June 15, September 15, December 15). These are based on the previous year’s liability or an estimate of the current year’s profit.

Penalties:

• Late Filing: A flat fee (e.g., GYD 50,000) plus a surcharge of 10% on the tax outstanding.
• Late Payment: Interest accrues at 18% per annum, plus a penalty of 2% per month on the unpaid tax. These compounds quickly, making non-compliance expensive.

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4. Special Fiscal Regimes: Mining and Manufacturing

Guyana’s economy is resource-heavy, and the tax code reflects this through sector-specific regimes that deviate from the standard corporate tax rules.

4.1 The Mining Sector (Gold and Diamond)

The mining sector operates under a specific withholding tax mechanism designed to capture revenue at the point of sale, given the high informality of the sector.

• Tributors’ Tax: A withholding tax of 10% is levied on tributors (miners working on claims owned by others).
• Gold Declaration: The Guyana Gold Board deducts relevant royalties and taxes upon declaration. The royalty rate fluctuates based on the world market price of gold (typically 5% to 8%).
• Withholding Tax on Gold: Specific codes exist for WHT on gold transactions, calculated on the gross value.

4.2 Manufacturing Incentives

To combat “Dutch Disease” (where the oil sector renders other sectors uncompetitive), the government utilizes the Fiscal Enactments (Amendment) Act to offer deep concessions.

• Customs & VAT Waivers: Manufacturers are exempt from Customs Duty and VAT on raw materials, packaging materials, and plant/machinery used in production.
• Tax Holidays: Companies engaged in “pioneering activities” (developmental and risk-bearing) can be granted a corporate tax holiday for up to 10 years. This completely exempts them from corporate tax for the duration, subject to approval by the Minister of Finance.

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5. The Petroleum Fiscal Regime: A State Within A State

The fiscal framework governing the oil and gas sector, specifically the Stabroek Block, effectively operates as a “state within a state.” It is governed by the 2016 Production Sharing Agreement (PSA) signed between the Government of Guyana (GoG) and the consortium of ExxonMobil (Esso), Hess, and CNOOC. This contract overrides general tax laws through stability clauses.

5.1 The Anatomy of the PSA Fiscal Terms

The economic model of the PSA is designed to incentivize the massive upfront capital investment required for ultra-deepwater exploration.

The Revenue Waterfall:

1. Gross Production: All oil extracted.
2. Royalty (2%): The contractor pays a royalty of 2% on gross production. There has been intense debate regarding the mechanics of this payment. While Article 15.6 states the contractor shall pay it, critics argue it is economically borne by the government because it is a deductible expense in calculating profit oil. However, structurally, it is a “off the top” payment before cost recovery.
3. Cost Recovery (75% Cap): The contractor is entitled to take up to 75% of the monthly production volume to recover “Recoverable Contract Costs.” These include exploration, development, and operating costs.

• Carry Forward: Unrecovered costs in any month are carried forward to the next month indefinitely until recovered.
• Audit Disputes: This mechanism relies on accurate cost reporting. Recent audits by IHS Markit (1999-2017) and a second audit (2018-2020) have disputed over US$214 million and US$65.1 million in costs, respectively. These disputes trigger the PSA’s arbitration and sole expert mechanisms.

4. Profit Oil (The Split): The remaining oil (at least 25% of production, assuming the cost cap is hit) is termed “Profit Oil.” This is split 50/50 between the Government and the Contractor.

5.2 The “Pay on Behalf” Mechanism (Article 15.4)

This is the single most controversial and complex element of the Guyanese oil tax regime, with profound implications for US tax relations.

The Mechanism:

Under Article 15.4 of the PSA, the Contractor is nominally subject to Income and Corporation Tax. However, the Agreement stipulates that the Government’s share of Profit Oil includes the satisfaction of the Contractor’s tax liability.

• Execution: The Minister responsible for Petroleum pays the taxes to the GRA on behalf of the contractor using the government’s own share of the oil revenue.
• Receipting: The GRA then issues tax certificates to Exxon, Hess, and CNOOC stating that taxes have been paid.
• Economic Reality: The contractor pays 0% corporate tax from their own cash flow. Their 50% profit share is effectively after-tax.

Strategic Intent: The US Foreign Tax Credit (FTC):

This convoluted structure was engineered to allow the US oil majors to claim Foreign Tax Credits under IRC Section 901. If the government simply exempted them from tax, they would pay 21% tax in the US on their Guyana profits. By characterizing the government’s take as “tax paid on behalf,” the companies attempt to generate a credit that offsets their US liability.

• Senate Inquiry: In 2024 and 2025, US Senators Whitehouse, Van Hollen, and Merkley launched a probe into this arrangement, questioning whether these payments qualify as creditable taxes or are merely disguised royalties (payments for a specific economic benefit). If the IRS determines these are “non-creditable payments” under the “dual capacity” taxpayer rules, the US companies could face a massive unexpected tax bill in the US, fundamentally altering the project economics.

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6. Interaction with the United States Tax Code

The fiscal relationship between Guyana and the United States is defined by a patchwork of information exchange agreements and the absence of a comprehensive Double Taxation Treaty (DTT). This creates a high-friction environment for cross-border investment.

6.1 The Absence of a Tax Treaty

Unlike Canada and the UK, the United States does not have a DTT with Guyana.

• Implication for Investors: There is no treaty-based reduction of Withholding Tax. US investors face the full 20% WHT on dividends, interest, and royalties, compared to 15% or 10% for Canadian or UK investors.
• Implication for Expatriates: There is no “tie-breaker” rule for residency. A US citizen who becomes a Guyanese resident is fully liable to Guyanese tax on worldwide income (subject to local remittance rules) and remains fully liable to US tax on worldwide income.

6.2 Mechanisms for Relief: Unilateral Credits

Without a treaty, relief from double taxation relies entirely on domestic laws.

• For US Persons: They must utilize the Foreign Tax Credit (FTC) (Form 1116) or the Foreign Earned Income Exclusion (FEIE) (Form 2555). The FEIE allows the exclusion of up to $120,000+ (indexed) of foreign earned income from US tax, provided the taxpayer meets the “Bona Fide Residence” or “Physical Presence” tests.
• For Guyanese Persons: Guyana offers a unilateral credit for foreign taxes paid, but this is limited to the amount of Guyanese tax payable on that foreign income.

6.3 FATCA and Information Exchange

Transparency is enforced through the Foreign Account Tax Compliance Act (FATCA) Intergovernmental Agreement (IGA) signed in 2016 and the Tax Information Exchange Agreement (TIEA) of 1992.

• Reporting: Guyanese financial institutions are legally mandated to identify US account holders and report their balances to the GRA, which automatically forwards this data to the IRS.
• Consequence: There is zero opacity. US citizens cannot hide Guyanese income. The TIEA ensures that the IRS has full visibility into the financial activities of US persons in Guyana.

6.4 Deep Dive: IRC Section 901 and Dual Capacity Taxpayers

The friction point for the oil sector lies in IRC Section 901 and Regulation 1.901-2.

• Dual Capacity Taxpayer: A taxpayer who pays a levy to a foreign government and receives a specific economic benefit (like an oil concession) is a “dual capacity taxpayer.”
• Burden of Proof: Such taxpayers must establish the distinct element of the levy that is a “tax” versus the payment for the benefit. The IRS “Safe Harbor” method often requires showing that the foreign tax is imposed generally.
• The “Soak-Up” Tax Rule: A tax is not creditable if it is a “soak-up” tax—one that is imposed only because the credit exists. The Guyana “Pay on Behalf” system risks being classified as such or as a non-tax payment because the liability is discharged by the government itself, not the taxpayer’s own funds.

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7. Knowledge Base: Withholding Tax Codes and Payments

For compliance officers and foreign companies, navigating the Withholding Tax (WHT) regime is the daily operational challenge. WHT is a final tax on gross payments.

7.1 WHT Rates Matrix

Payment Type	Recipient: Resident	Recipient: Non-Resident (Standard)	Recipient: Non-Resident (Company Contractor)
Dividends	0%	20%	N/A
Interest	0% (Individual) / 20% (Company)	20%	N/A
Royalties	N/A	20%	N/A
Management Fees	N/A	20%	N/A
Contract Services	2% (Resident Contractor)	N/A	10% (Section 10B)

7.2 The 10% Non-Resident Contractor Tax (Section 10B)

This tax applies to “contract undertakings.”

• Definition: The supply of goods or services for reward.
• Base: Gross payment. No deductions for costs incurred by the foreign contractor.
• Strategic Risk: A US service company billing $1 million for engineering work will receive $900,000. If their profit margin is only 10%, the entire profit is consumed by the Guyanese tax. This necessitates “grossing up” clauses in contracts to pass the tax burden to the local client.

7.3 Gold and Mining WHT Codes

The GRA uses specific codes for mining payments to track the flow of minerals.

• Gold: WHT is often calculated on the gross value of the gold declared.
• Codes: Specific payment codes exist for “Quantity – Ozs,” “Quantity – Dwts,” and “Total Price – US” on WHT returns to facilitate the royalty and tax calculation at the Gold Board level.

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8. Strategic Analysis: Strengths, Weaknesses, and Future Outlook

8.1 Systemic Strengths

1. Investment Attractiveness: The combination of tax holidays, duty-free imports for manufacturing, and the 100% write-off for green energy creates a powerful incentive package for capital-intensive non-oil industries.
2. High-Income Talent Retention: The “1/3 Free Pay” personal allowance is a structural masterstroke for retaining the burgeoning class of oil executives and local professionals. By ensuring the effective tax rate drops as income rises, Guyana competes effectively with low-tax jurisdictions for talent without nominally being a tax haven.
3. Revenue Stability (Oil): Despite the controversy, the 2% royalty on gross oil production guarantees government revenue from the first barrel, insulating the state somewhat from the volatility of “profit oil” which depends on cost recovery.

8.2 Systemic Weaknesses

1. The Commercial Distortion: The 15-point spread between Commercial (40%) and Non-Commercial (25%) corporate tax rates is a major distortion. It encourages aggressive transfer pricing and entity fragmentation to shield profits in “non-commercial” subsidiaries.
2. Treaty Isolation: The lack of a US Tax Treaty is a glaring vulnerability. It leaves US investors exposed and increases the cost of capital due to high WHT rates.
3. Administrative Capacity: As noted by the IMF and World Bank, the GRA faces significant challenges in auditing the complex cost recovery claims of oil majors. The reliance on third-party auditors (like IHS Markit) underscores the need for massive capacity building.
4. The “Pay on Behalf” Fragility: The entire fiscal logic of the US oil majors in Guyana rests on the stability of the US Foreign Tax Credit claim. A shift in IRS policy or US legislation could destabilize the economics of the Stabroek Block.

8.3 Future Outlook

The fiscal trajectory of Guyana is one of continued reform. The 2025 budget’s reduction in individual rates signals a political willingness to distribute the oil windfall through the tax code. However, the long-term sustainability of the state requires broadening the non-oil tax base. We can expect future legislative moves to harmonize the corporate tax rates, potentially lowering the commercial rate to align with the non-commercial sector, funded by the expanding oil revenues. Furthermore, pressure will likely mount for a formal Double Taxation Treaty with the United States to regularize the status of the billions of dollars in cross-border flows defining the new Guyanese economy.