Representatives of the governments of the Netherlands and Curaçao on 12 December 2013 reached an agreement on a new regulation for the avoidance of double taxation between the two countries (referred to as the BRNC).
As announced by the Dutch Ministry of Finance, the intention is for the BRNC—after ratification—to replace the existing tax regulation currently applying between Curaçao and the Netherlands by 1 January 2015.
The text of the BRNC has not yet been made public, but the main features have been published and include:
• Changes to the taxation of dividends;
• New rules for the taxation of non-government pensions;
• Anti-abuse measures;
• Introduction of new rules for hybrid entities;
• Rules for determining permanent establishments; and
• Gift and inheritance provisions.
