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Energy-sector taxation in Guyana: corporation tax, withholding and agreement-specific relief

Tax

13 November 2026Fraser & Housty

Corporation tax rates

The Guyana Revenue Authority publishes the corporation tax rates applied under the Corporation Tax Act. Commercial companies (other than telephone companies) are charged at 40 per cent, telephone companies at 45 per cent, and any other company at 25 per cent. A company that carries on both commercial and non-commercial activities may be charged at both rates on the respective parts of its chargeable profits. Those are the general statutory rates. They apply unless a particular written law, or a term of an applicable agreement that is effective as a matter of law, provides otherwise. A contractor or supplier should not assume that energy-sector activity is taxed at a special statutory rate simply because the work is performed for a petroleum licensee.

Withholding on payments to non-resident companies

Section 10B of the Corporation Tax Act requires a person who makes a payment to a non-resident company in respect of a contract undertaking to deduct tax at 10 per cent of the payment and to remit the amount deducted to the Commissioner-General within 30 days. The GRA’s withholding-tax materials should be checked for the current treatment of the particular category of payment. Other withholding obligations may also arise under the Income Tax Act, depending on the nature of the payment (for example, interest, dividends or other income of a non-resident). The obligation to deduct, and the rate, should be confirmed against the statute and current GRA guidance before a payment is made. The standard rate of value-added tax, under regulation 2 of the Value-Added Tax Regulations as they appear in the official text of the Value-Added Tax Act (Cap. 81:05, L.R.O. 1/2022), is fourteen per cent of the tax imposed under section 9(1) of that Act (as substituted by Regulations No. 8 of 2016). This review has not identified a later amendment of that standard rate. Schedule amendments notified by the GRA with effect from 16 February 2026, described in the firm’s [note on investment incentives](/insights/investment-incentives-and-foreign-investment-legislation-in-guyana), alter zero-rating and exemption lists, not that rate.

Customs, VAT and agreement-specific fiscal terms

Customs duty and value-added tax are, as a starting point, matters of general law administered by the GRA. In the petroleum sector, however, fiscal terms are often also set out in the petroleum agreement. The GRA has issued guidance in relation to the 2016 petroleum agreement with Esso Exploration and Production Guyana Limited and its co-venturers, including as to duty- and VAT-free importation of equipment and supplies for petroleum operations under Article 21.1 of that agreement, subject to the exclusions stated in that guidance (including foodstuffs, alcoholic beverages and fuel). That treatment is specific to the agreement to which the guidance relates. It is not a general statutory exemption for all energy contractors and suppliers, and it should not be applied by analogy to a different contract or a different operator without confirming the applicable instrument and the GRA’s current position.

The GRA also administers value-added tax, customs, excise and related revenue matters. A contractor or supplier establishing a presence in Guyana will ordinarily need to consider taxpayer registration, and value-added-tax registration where that regime applies, together with employment and payroll obligations, customs classification and valuation on imported equipment and supplies, and record-keeping and filing. Those are general requirements. They are not displaced merely because the work is performed in the energy sector.

From 1 January 2026, the GRA has advised that, in accordance with section 7 of the Corporation Tax Act, income arising from agriculture and agro-processing, and income arising from child-care and elderly-care services, of companies (not individuals) is exempt from corporation tax. That exemption is not a general energy-sector relief. The same GRA notice records that, also from 1 January 2026, timber was removed from Part III of the Fifth Schedule to the Income Tax Act, so that export of timber by companies may qualify for the export allowance. Those changes, and the wider incentive statutes, are discussed in the firm’s [note on investment incentives](/insights/investment-incentives-and-foreign-investment-legislation-in-guyana).

A contractor or supplier tendering for energy-sector work should therefore distinguish three questions: what the general tax statutes require; what, if anything, the particular petroleum agreement or licence provides; and what, if any, written confirmation the GRA has given in relation to that agreement. Those questions also need to be read with the Petroleum Activities Act 2023, under which a petroleum agreement is authorised, and with any applicable local content obligations. Tax advice is best taken before agreements are signed or funds are transferred.

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