Curaçao: Double Tax Treaties
NB: The Netherlands Antilles as such ceased to exist in October 2010. This page deals with Curaçao, the largest component of the jurisdiction, which has taken its place in many respects.
The Netherlands Antilles had tended to move away from double tax treaty arrangements during recent years, but seems to have actively reversed this policy, having commenced tax treaty negotiations with about a dozen countries since late 2006. At one time the country had treaties with a number of prominent countries, including the US and the UK. Most of these treaties have lapsed, and the only remaining double tax treaty as such are with Aruba and Norway. There is also the 'BRK' tax agreement with the Netherlands. After negotiations to continue the US treaty failed in 1987, the remaining 'mini-'Treaty' continues to give exemption from US withholding taxes to Eurobonds issued before 1984.
The Netherlands Antilles has signed Tax Information Exchange Agreements with Australia, New Zealand, the USA, Canada, Spain,Mexico, Denmark, Iceland, Finland, France, Sweden, Mexico, the UK, Greenland and the Faroe Islands, as well as the Caribbean Islands of St Lucia, Antigua & Barbuda, Bermuda, Cayman, Saint Vincent and the Grenadines, British Virgin Islands and St Kitts & Nevis.
In 2008, the Secretary of State for Finance, Alex Rosaria explained that:
"The importance of TIEAs is the positive positioning of the Netherlands Antilles. These agreements confirm the Netherlands Antilles’ commitment to high international standards and its stature as a responsible international financial center."
"Since 2000, the Netherlands Antilles has worked with the OECD countries to develop principles to improve transparency and exchange of information in tax matters."
The statement went on to add that: "Although of vital importance, TIEAs are do not particularly bring about new economic activities for the international financial services sector."
"Furthermore there is a growing number of smaller countries that do question the benefits of TIEAs given the fact that there is no level playing field. It is hoped that this theme will shortly be discussed within the OECD."
"DTAs on the other hand do contribute to economic activity because they focus on stimulating investments."
Rosaria went on to stress again that the Netherlands Antilles must concentrate more on the negotiating and entering into DTAs, concluding that:
“The sector also agrees with me that the ‘beef’ is to be had in DTA’s. I expect that we can this year negotiate DTA’s with Mexico, Spain, Surinam, the United Arab Emirates and Colombia."