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Curacao’s economic zones

If your company is located in one of curacao’s economic zones (E-Zones) you only have to pay 2% tax on your profits. This is guaranteed to be the case until the year 2026.

This legislation was introduced in 2001, in order to stimulate the economy of Curacao. The economic zones are meant for export businesses with or without the movement of goods. E-Commerce businesses are included in this! There’s a requirement that 75% of your profit isn’t made on the islands itself, so if you make your money anywhere else but on the antilles, this might be something for you.

How does it work?

This depends on the country you’re in. You should start a dutch business (NV or BV) and an Antillian NV. The dutch NV or dutch BV are treated like a legal person in the dutch law.

Now, the antillian NV is the business you use to make money with. All your profits are taxed with just 2%. If the “owner” of the antillian NV is a ‘Stichting particulier fonds’ (SPF) (Private fund foundation), you don’t have to pay taxes on the dividend you pay out to the SPF. The SPF doesn’t have to withhold any tax when paying out to third parties. The third party in this case is the dutch business you’ve set up. Because Holland has tax treaties with curacao, you don’t get taxed again when your money arrives in Holland.

Let’s give an example to clear things up:

Your business makes a before-tax profit of $500.000. Because your business is an antillian NV, you have to pay 2% tax on your profits to the antillian goverment ($10.000). This leaves the profits at $490.000 which you pay out as dividend to the “owner” of the business, which is the SPF (Private fund foundation). Because it’s a foundation, you get to pay out all of the $490.000 taxfree and, again because it’s a foundation, you can pay out the profit taxfree from the SPF to your dutch business.

Sounds pretty good eh?

The SPF is generally set up and managed by a trustcompany, to give the real owner complete anonymity. This is also necessary in most cases, because the trustcompany is located on the antilles. This system only works when the owner of the SPF is an inhabitant of the antilles, so it’s either using a trustcompany, or moving to Curacao.

So my money is in Holland, now what?

Good question, this depends on your country. If Holland has tax treaties with your country, you can transfer the money from Holland to your country, usually tax free. Holland has tax treaties with many countries, including the UK and the US, however the treaty with the US recently changed so you may want to read up on it or ask your financial planner.

Celebrities use it too

The rolling stones, U2 and david bowie just to name a few, are all using holland (and probably curacao as well, only confirmed for the rolling stones) to pay less taxes. This is legal, it’s tax avoidance, not tax evasion!

Disclaimer

I don’t use this construction myself (yet) but this is how I understand it works, based on what several accountants and a trust company told me. If you want to setup something like this, talk to your financial planner / accountant / whoever first.

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