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Curaçao: Double Tax Treaties

Netherlands Tax Treaty

This page was last updated on 6 September 2019.

Previously, the ‘Kingdom Tax Agreement’ (Belastingregeling voor het Koninkrijk or BRK) applied to all constituent parts of the Kingdom of the Netherlands, that is, the countries of the Netherlands, Curaçao, Aruba and St. Maarten.

On 1 January 2016, the Belastingregeling tussen Nederland en Curaçao (BRNC) came into force. This is a tax treaty exclusively between Curaçao and the Netherlands and governs tax relations between these two countries. The BRK is still in force with respect to relations between Curaçao and Aruba and Curaçao and St. Maarten.

The BRNC stipulates that there is a 0% dividend withholding tax rate if the beneficial owner of the dividends is:

  1. An entity that holds at least 10% of the distributing entity’s capital and is either of the following:
    • (a) deemed a qualifying entity
    • (b) at least 50% held by individual residents in one of the states.
  2. A state, political division or municipality.
  3. A pension fund.

Additionally, a 5% rate applies if the beneficial dividend owner is an entity resident in Bonaire, St. Eustatius or Saba. In all other situations, the withholding tax rate is 15%. Interest and royalties may be taxed in both resident and source state in some circumstances.

Corporations based in Aruba and St. Maarten must withhold 8.3% dividend withholding tax (at the time of writing) from the gross dividend. The 8.3% which has been withheld on dividend distribution in these countries can be credited against tax in Curaçao.

Dividends and capital gains derived from shareholdings in an Aruba or St. Maarten corporation are fully exempted from profit tax in Curaçao, provided the shareholding amounts to at least 25% and that the dividend is subject to Curaçao tax of at least 8.3% on the gross amount of dividends received.



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