Individual residence and Grenadian-source income

Presence, permanent abode and adjacent years

Residence can arise from at least 183 days of physical presence in the assessment year, or a permanent Grenadian abode with some presence. Accepted education, medical, government-duty or other reasonable absence can preserve the abode basis throughout a year away. A further rule covers continuous presence connected with an immediately adjoining year qualifying under the day test.

Resident and nonresident source-based charge

Section 8 includes non-exempt income from all Grenadian sources for residents and, subject to the withholding rules, nonresidents. It does not state a general worldwide-income charge on resident individuals. Citizenship is not a substitute for applying these residence and source provisions.

Where work and connected services arise

Employment exercised in Grenada can be Grenadian-source regardless of payment or contract location. The Act also sources specified overseas employment of an ordinarily resident person to Grenada when its expense is charged against a Grenadian business, and covers management or technical services borne by a Grenadian business. A foreign payer or account alone is not decisive.

Foreign activity linked to Grenadian business

For a business conducted inside and outside Grenada, the Comptroller determines a reasonable Grenadian-source amount using the operations, turnover, assets and other relevant factors. Income arising abroad from an act incidental to business carried on in Grenada is included whether received in Grenada or not.

Nonresident withholding is a separate mechanism

As amended in 2015, section 7(5) removes covered nonresident income from ordinary assessable income when it is not from carrying on business and instead subjects it to withholding under sections 50 or 51A. This distinction is not an exemption from tax; particular payment categories, exemptions and agreements must still be checked.

Applicable agreements can modify the result

Section 43 authorises agreements addressing double taxation, permanent-establishment income and source allocation. An agreement, amendment or cancellation must be published by Gazette order; an effective agreement operates notwithstanding inconsistent provisions of the Act. Relief therefore depends on the particular applicable agreement, not nationality alone.