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Aruba: Double Tax Treaties

Netherlands Tax Treaty

This page was last updated on 25 Feb 2019.

Provisions under the New Fiscal Regime and a revised 'BRK' (tax treaty with the Netherlands) came into effect from 1 July 2003. They include:

  • dividends from a Dutch corporation to Aruba corporate shareholders, who own at least 25% of the shares in the Dutch corporation, will be exempted from Dutch dividend withholding tax, provided that the dividend is subject to Aruban tax at a rate of at least 8.3%.
  • the Dutch corporation will have to withhold 8.3% dividend withholding tax from the gross dividend. The 8.3% which has been withheld upon the dividend distribution in the Netherlands can be credited against tax in Aruba.
  • dividends and capital gains derived from shareholdings in a Netherlands corporation will be exempted from additional profit tax in Aruba provided that the shareholding amounts to at least 25% and that 8.3% Aruba tax is paid on the gross amount of dividends received.
  • dividends paid by Dutch corporations to Aruban corporations unable to take advantage of the participation exemption will be subject to 15% Dutch dividend withholding tax. Existing Aruban offshore corporations may elect for the new dividend treatment.
  • the activities of an exempted company (AEC) will be restricted to investments in debt instruments, securities and deposits.



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