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Curaçao: Double Tax Treaties

The Norway Double Tax Treaty

The Netherlands Antilles Double Tax Treaty with Norway has been effective since 1990, it is based on the OECD model treaty and continues to apply to the newly independent Curaçao. Withholding tax on dividends from a Norwegian company are reduced; there is anyway no Norwegian withholding tax on interest, and there are no Antillean withholding taxes at all. (However, the New Fiscal Framework applying from 2002 includes provision for a 10% withholding tax on profit distributions by Antillean companies, although this has so far not come into effect).

There are some exceptions to the treaty withholding tax regime, with relief being unavailable to:

  • Companies that do not have a genuine business purpose in the Netherlands Antilles and less than 50% of whose shares are held in the two countries;
  • Companies claiming 'offshore' status under Articles 14 and 14A of the National Ordinance on Profit Tax 1940.

Articles 14 and 14A are being repealed for new formations, and companies incorporated as NABVs under the New Fiscal Framework will not have access to double taxation treaties.

 

 

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