THE NETHERLANDS ANTILLES OFFERS HIGHLY ATTRACTIVE TAX BENEFITS
Effective tax rate of 1.725%
From one of the weblog’s visitors I received this question: Is it possible to structure the revenue of a global company such that all money goes through a tax friendly environment (such as the Netherlands Antilles), prior to being distributed to the respective national corporations?
Curaçao certainly offers attractive possibilities for intermediate holding companies. This could be a fully taxed entity that, however, qualifies for the so called participation exemption under which the advantages from qualifying subsidiaries are exempt for 95%, thus creating an effective tax rate of 1.725%.
It also could be a so called Exempt company that has to limit its activities to investing and financing.
In both cases dividend payments to the national corporation will not be hit with a withholding tax since this does not exist.
Karel Frielink
Attorney (lawyer) / Partner
