Proposed new Tax Arrangement between the Netherlands and Curaçao submitted to the Dutch House of Representatives

This proposed new Tax Arrangement between the Netherlands and Curaçao (“TANC”) will replace the current Tax Arrangement for the Kingdom of the Netherlands (“TAK”).

Background

Since 10 October 2010, when the Netherlands Antilles were dissolved, Curaçao is a constituent country of the Kingdom of the Netherlands. On 12 December 2011, the Dutch Ministry of Finance announced that the Netherlands and Curaçao had reached an agreement in headlines on a new bilateral tax arrangement for the avoidance of double taxation which should replace the current multilateral tax arrangement for the Kingdom of the Netherlands in relation between the Netherlands and Curaçao. As a result of the changes in October 2012 the TANC indicates that it is also applicable between Curaçao and Bonaire, Saint Eustatius and Saba. However, it is not applicable to Aruba and Sint Maarten. The current TAK (“Belastingregeling voor het Koninkrijk”) will remain applicable between the Netherlands and Aruba and between the Netherlands and Sint Maarten.

On 10 June 2014, the bill to implement to TANC submitted to the Dutch House of Representatives was published. The TANC will enter into force on 1 January following the year of ratification in the Netherlands and Curaçao. It is expected that the ratification will take place this year. Therefore, it is expected that the TANC will enter into force as per 1 January 2015. The TANC is based on the OECD Model Tax Convention.

Read more in the below attachment.