If you have a company and have to pay a lot of corporation tax in the Netherlands, it might be a good idea to consider the options for establishing your business in Curaçao. Whereas in the Netherlands the low rate is currently 19%, the fixed rate in Curaçao is only 2%. This is because there are so-called E-zones in Curaçao that enable the establishment of companies for tax purposes. In these E-zones, the corporation tax rate is guaranteed 2% until 1 January 2026.
To establish in these E-zones and to be eligible for the favourable rate, a few conditions apply.
The shareholders of a company established in Curaçao can submit a request to apply the E-zone regime. For this, the company must be registered with the Curaçao Chamber of Commerce. The request is submitted to the Ministry for Economic Development and must meet certain conditions. In this way, it is important to attach a customs declaration and a concise business plan to the request.
It must be a company that acts in an international context. Products do not have to be traded via the port in Curaçao; this can be done directly from the producer to the buyer.
Company with share capital
The company must be a company with capital divided into shares, that has been established by a notarial deed. Dutch examples of this are the BV and the NV. This may also be a joint venture or a branch of such a company that is established in the E-zone.
Trade with international clients
The company’s activities must focus primarily on trading with customers who are not based in Curaçao. Delivering to customers on Curaçao is only permitted if the authorities give specific permission for this.
Actual management in Curaçao
The actual management or direction of the company must be in Curaçao. It is not necessary for the direction that this is a natural person, it is also possible to engage a legal person (such as a trust office) as the direction.
The provision of services has been excluded from establishment in the E-zones, unless the service falls under a legal exception. Think especially of maintenance or repair work within the E-zone.
The activities that your company carries out must contribute to the economic growth of the Netherlands Antilles. This means that it is important that you make a profit or that you make a substantial contribution to employment.
In addition to the very favourable rate for corporation tax, there are a few other advantages associated with establishing a business on Curaçao. For example, the distance to buyers in the US and South America is a lot smaller and a large part of the population speaks Dutch, English and Spanish. The level of education is also relatively good and the wage costs are relatively low. Finally, there are still some tax benefits for companies that are located in the E-zone: the import of goods is exempt from import duties and sales tax and delivery to customers outside of Curaçao is exempt from Dutch Antillean sales tax.
Please note that it is important to obtain good tax advice, because the Dutch tax authorities are watching critically. We can advise on this.