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Curaçao: Offshore Business Sectors

Holding Companies

Offshore holding or investment companies are defined in the National Ordinance on Profit Tax 1940 as companies that have the 'exclusive or almost exclusive purpose of investing their assets in securities, including shares and other certificates of participation and bonds, as well as other claims for interest-bearing debts however nominated and in whatever form'. See Offshore Tax and Legal Regimes for details of the tax treatment of such companies.

Curaçao holding companies are often used to hold the shares of Dutch corporations which are themselves the holding companies for investments or group operating subsidiaries in third countries, thus making use of the very wide network of Dutch Double Tax Treaties, and the permissive Dutch rules on withholding tax.

Curaçao companies which provide financing for other companies need a license from the central bank; but such a company established as part of a group financing structure can qualify as a 'Concern-Financing Corporation' which does not require a license if:

  • it receives at least 90% of its funding from the group, and any bearer bonds it issues are limited to institutional investors; or
  • its loans are only to group companies, and the parent company of the group has provided a guarantee to the central bank to cover its external borrowing.

 

 

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