🇨🇼 Curacao

Latin America & Caribbean ·

Curacao has implemented statutory interest limitation rules and statutory country-by-country reporting requirements. The jurisdiction does not have controlled foreign company rules in place.Auto-generated summary of the verified data below; every fact traces to a source on this page.

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enforcement powers assessed

Enforcement powers

Controlled foreign company (CFC) rules  No — power absent

Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).

“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — No”

Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer

Interest limitation rules  Yes — statutory power

Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).

“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Regime 1" — Yes”

Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer

Country-by-country reporting  Yes — statutory power

Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).

“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”

Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer

Mandatory disclosure rules  No — power absent

Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).

“OECD Corporate Tax Statistics: "Is there mandatory disclosure rules requiring the disclosure of Common Reporting Standards (CRS) avoidance or aggressive tax planning arrangements? · Not applicable" — No”

Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer

Anti-avoidance regime detail (OECD Corporate Tax Statistics)

OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation and CbCR rules. IP regimes are covered in their own section below.

CFC rules — 2 data points
Is there a controlled foreign company rule in place? · Regime 1No
Is there a controlled foreign company rule in place? · Not applicableNo
Interest limitation — 70 data points
Do any loss carry-back or carry-forward provisions apply? · Regime 1No
Do any loss carry-back or carry-forward provisions apply? · Regime 2No
Do any loss carry-back or carry-forward provisions apply? · Rule 1No
Do any loss carry-back or carry-forward provisions apply? · Rule 2No
Is a de minimis threshold present? · Regime 1No
Is a de minimis threshold present? · Regime 2N
Is a de minimis threshold present? · Rule 1None
Is a de minimis threshold present? · Rule 2None
Any other exclusions? · Regime 1Yes
Any other exclusions? · Regime 2No
Any other exclusions? · Rule 1Yes
Any other exclusions? · Rule 2No
Exclusions based on payer characteristics? · Regime 1No
Exclusions based on payer characteristics? · Regime 2No
Exclusions based on payer characteristics? · Rule 1No
Exclusions based on payer characteristics? · Rule 2No
Exclusions based on payment characteristics? · Regime 1No
Exclusions based on payment characteristics? · Regime 2No
Exclusions based on payment characteristics? · Rule 1No
Exclusions based on payment characteristics? · Rule 2No
Exclusions based on recipient characteristics? · Regime 1No
Exclusions based on recipient characteristics? · Regime 2Yes
Exclusions based on recipient characteristics? · Rule 1No
Exclusions based on recipient characteristics? · Rule 2Yes
Financial accounting measure applied to rule · Regime 1sound business principles
Financial accounting measure applied to rule · Regime 2debt to equity
Financial accounting measure applied to rule · Rule 1sound business principles
Financial accounting measure applied to rule · Rule 2debt to equity
Is there a group ratio rule or similar type of rule in place? · Regime 1No
Is there a group ratio rule or similar type of rule in place? · Regime 2No
Is there a group ratio rule or similar type of rule in place? · Rule 1No
Is there a group ratio rule or similar type of rule in place? · Rule 2No
Is there an interest limitation rule in place? · Regime 1Yes
Is there an interest limitation rule in place? · Regime 2Yes
Is there an interest limitation rule in place? · Rule 1Yes
Can interest be recharacterised as a dividend? · Regime 1No
Can interest be recharacterised as a dividend? · Regime 2No
Can interest be recharacterised as a dividend? · Rule 1No
Can interest be recharacterised as a dividend? · Rule 2No
Is the rule is applicable to net or gross interest expensing? · Regime 1gross interest expense
Is the rule is applicable to net or gross interest expensing? · Regime 2gross interest expense
Is the rule is applicable to net or gross interest expensing? · Rule 1Gross interest expense
Is the rule is applicable to net or gross interest expensing? · Rule 2Gross interest expense
Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Regime 1No specific mechanisms
Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Regime 2No specific mechanisms
Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Rule 1No specific mechanisms
Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Rule 2No specific mechanisms
Is the rule applicable to related party debt? · Regime 1Yes
Is the rule applicable to related party debt? · Regime 2Yes
Is the rule applicable to related party debt? · Rule 1Yes
Is the rule applicable to related party debt? · Rule 2Yes
Description of interest limitation rule · Regime 1When determining the profit, interest including costs and currency results on loans owed to an entity belonging to the same group shall not be deductible insofar as the loan relates to one of the following legal acts: a. a distribution of profits or a refund of paid-up capital by the taxpayer; b. an acquisition of including payment into shares, certificates of participation, or members…
Description of interest limitation rule · Rule 1When determining the profit, interest—including costs and currency results—on loans owed to an entity belonging to the same group shall not be deductible insofar as the loan relates to one of the following legal acts: a. a distribution of profits or a refund of paid-up capital by the taxpayer; b. an acquisition of — including payment into — shares, certificates of participation, or membership ri…
Type of interest limitation rule · Regime 1base is the sound business principles
Type of interest limitation rule · Regime 2thin cap rule
Type of interest limitation rule · Rule 1base is the sound business principles
Type of interest limitation rule · Rule 2thin cap rule
Financial ratio referenced · Regime 1Not applicable
Financial ratio referenced · Regime 20.12569444444444444
Financial ratio referenced · Rule 23:1
Is the rule is applicable to third party debt? · Regime 1No
Is the rule is applicable to third party debt? · Regime 2No
Is the rule is applicable to third party debt? · Rule 1No
Is the rule is applicable to third party debt? · Rule 2No
Are there targeted rules to address specific risks not addressed by the general rule? · Regime 1No
Are there targeted rules to address specific risks not addressed by the general rule? · Regime 2No
Are there targeted rules to address specific risks not addressed by the general rule? · Rule 1No
Are there targeted rules to address specific risks not addressed by the general rule? · Rule 2No
Year of introduction of the interest limitation rule · Rule 12001
Year of introduction of the interest limitation rule · Rule 22001
Country-by-country reporting — 5 data points

The OECD publishes this table without a reference year, so these entries are undated at source.

Is there a country-by-country reporting law in place?Yes
Further informationVoluntary parent surrogate filing is or was available for earlier fiscal years.
Deadline by which filings must be submitted12 months
Reports are required for MNEs with annual revenues aboveNAFI 1.5 billion
Headquarter jurisidiction filing required from01-Jan-18

IP regimes

Patent-box and innovation-box preferential rates for qualifying IP income, as curated by the OECD Corporate Tax Statistics / QDD database. Each regime is shown as most recently reported; regimes the OECD records as abolished are kept and marked, not dropped.

Innovation box

As most recently reported for 2026.

Qualifying income is taxed at 0.00% under this regime, against a headline rate of 22.00%.

Qualifying assets: Patents, Software, Category 3.

OECD Forum on Harmful Tax Practices assessment: Not harmful.

Curacao investment company (formerly Tax exempt entity)

As most recently reported for 2026.

Qualifying income is taxed at 0.00% under this regime, against a headline rate of 22.00%.

Qualifying assets: Patents, Software, Category 3.

OECD Forum on Harmful Tax Practices assessment: Not harmful (amended).

Export facilityAbolished

As most recently reported for 2018.

Qualifying income was taxed at 3.19% under this regime, against a headline rate of 22.00%.

Qualifying assets: Not restricted to three allowed asset categories.

OECD Forum on Harmful Tax Practices assessment: Abolished.

Effective corporate tax rates

MeasureYearRate
Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable202516.2%
Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable20254.9%
Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable202515.3%
Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable202519.6%
Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable202510.8%
Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable202519.1%
Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable202523.9%
Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable202520.7%
Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable202522.0%
Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable202519.0%
Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable202518.0%
Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable202522.4%
Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable202521.2%
Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable202521.6%
Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable202520.7%
Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable202520.0%
Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable202535.1%
Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable202523.5%
Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable202528.1%
Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable202517.2%
Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable202513.5%
Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable202531.8%
Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable202521.0%
Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable202524.4%
Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable202516.9%
Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable202510.9%
Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable20259.4%
Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Composite · Not applicable20258.6%
Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable20258.9%
Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable20258.2%
Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable20257.9%
Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable20254.0%
Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Composite · Not applicable20253.6%
Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Inventories · Not applicable20253.7%
Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable20253.5%
Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable20253.3%

OECD Corporate Tax Statistics, baseline scenario.