🇨🇼 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.
3/11
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
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 2 data points
| Is there a controlled foreign company rule in place? · Regime 1 | No |
| Is there a controlled foreign company rule in place? · Not applicable | No |
Interest limitation — 70 data points
| Do any loss carry-back or carry-forward provisions apply? · Regime 1 | No |
| Do any loss carry-back or carry-forward provisions apply? · Regime 2 | No |
| Do any loss carry-back or carry-forward provisions apply? · Rule 1 | No |
| Do any loss carry-back or carry-forward provisions apply? · Rule 2 | No |
| Is a de minimis threshold present? · Regime 1 | No |
| Is a de minimis threshold present? · Regime 2 | N |
| Is a de minimis threshold present? · Rule 1 | None |
| Is a de minimis threshold present? · Rule 2 | None |
| Any other exclusions? · Regime 1 | Yes |
| Any other exclusions? · Regime 2 | No |
| Any other exclusions? · Rule 1 | Yes |
| Any other exclusions? · Rule 2 | No |
| Exclusions based on payer characteristics? · Regime 1 | No |
| Exclusions based on payer characteristics? · Regime 2 | No |
| Exclusions based on payer characteristics? · Rule 1 | No |
| Exclusions based on payer characteristics? · Rule 2 | No |
| Exclusions based on payment characteristics? · Regime 1 | No |
| Exclusions based on payment characteristics? · Regime 2 | No |
| Exclusions based on payment characteristics? · Rule 1 | No |
| Exclusions based on payment characteristics? · Rule 2 | No |
| Exclusions based on recipient characteristics? · Regime 1 | No |
| Exclusions based on recipient characteristics? · Regime 2 | Yes |
| Exclusions based on recipient characteristics? · Rule 1 | No |
| Exclusions based on recipient characteristics? · Rule 2 | Yes |
| Financial accounting measure applied to rule · Regime 1 | sound business principles |
| Financial accounting measure applied to rule · Regime 2 | debt to equity |
| Financial accounting measure applied to rule · Rule 1 | sound business principles |
| Financial accounting measure applied to rule · Rule 2 | debt to equity |
| Is there a group ratio rule or similar type of rule in place? · Regime 1 | No |
| Is there a group ratio rule or similar type of rule in place? · Regime 2 | No |
| Is there a group ratio rule or similar type of rule in place? · Rule 1 | No |
| Is there a group ratio rule or similar type of rule in place? · Rule 2 | No |
| Is there an interest limitation rule in place? · Regime 1 | Yes |
| Is there an interest limitation rule in place? · Regime 2 | Yes |
| Is there an interest limitation rule in place? · Rule 1 | Yes |
| Can interest be recharacterised as a dividend? · Regime 1 | No |
| Can interest be recharacterised as a dividend? · Regime 2 | No |
| Can interest be recharacterised as a dividend? · Rule 1 | No |
| Can interest be recharacterised as a dividend? · Rule 2 | No |
| Is the rule is applicable to net or gross interest expensing? · Regime 1 | gross interest expense |
| Is the rule is applicable to net or gross interest expensing? · Regime 2 | gross interest expense |
| Is the rule is applicable to net or gross interest expensing? · Rule 1 | Gross interest expense |
| Is the rule is applicable to net or gross interest expensing? · Rule 2 | Gross interest expense |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Regime 1 | No specific mechanisms |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Regime 2 | No specific mechanisms |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Rule 1 | No specific mechanisms |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Rule 2 | No specific mechanisms |
| Is the rule applicable to related party debt? · Regime 1 | Yes |
| Is the rule applicable to related party debt? · Regime 2 | Yes |
| Is the rule applicable to related party debt? · Rule 1 | Yes |
| Is the rule applicable to related party debt? · Rule 2 | Yes |
| Description of interest limitation rule · Regime 1 | When 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 1 | When 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 1 | base is the sound business principles |
| Type of interest limitation rule · Regime 2 | thin cap rule |
| Type of interest limitation rule · Rule 1 | base is the sound business principles |
| Type of interest limitation rule · Rule 2 | thin cap rule |
| Financial ratio referenced · Regime 1 | Not applicable |
| Financial ratio referenced · Regime 2 | 0.12569444444444444 |
| Financial ratio referenced · Rule 2 | 3:1 |
| Is the rule is applicable to third party debt? · Regime 1 | No |
| Is the rule is applicable to third party debt? · Regime 2 | No |
| Is the rule is applicable to third party debt? · Rule 1 | No |
| Is the rule is applicable to third party debt? · Rule 2 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 1 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 2 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 1 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 2 | No |
| Year of introduction of the interest limitation rule · Rule 1 | 2001 |
| Year of introduction of the interest limitation rule · Rule 2 | 2001 |
Country-by-country reporting — 5 data points
| Is there a country-by-country reporting law in place? | Yes |
| Further information | Voluntary parent surrogate filing is or was available for earlier fiscal years. |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | NAFI 1.5 billion |
| Headquarter jurisidiction filing required from | 01-Jan-18 |
IP regimes — 16 data points
| Further information · Regime 1 | The regime is applicable for the following intangible assets: 1) in respect of which a patent or plant breeder�s right was granted to the taxpayer or for which an application was filed for a patent or plant breeder�s right; 2) which has the form of copyrighted software, protected by a patent for plant breeder�s right; 3) for which a license to sell a medicinal product was granted;4) for which a s… |
| Regime name · Regime 1 | Innovation box |
| Regime name · Regime 2 | Curacao investment company (formerly Tax exempt entity) |
| Regime name · Regime 3 | Export facility |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 1 | Not harmful |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 2 | Not harmful (amended) |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 3 | Abolished |
| Asset types that can qualify for the IP regime · Regime 1 | Patents, Software, Category 3 |
| Asset types that can qualify for the IP regime · Regime 2 | Patents, Software, Category 3 |
| Asset types that can qualify for the IP regime · Regime 3 | Not restricted to three allowed asset categories |
| Tax rate that would otherwise apply · Regime 1 | 22.00% |
| Tax rate that would otherwise apply · Regime 2 | 22.00% |
| Tax rate that would otherwise apply · Regime 3 | 22.00% |
| Reduced tax rate that applies under the IP regime · Regime 1 | 0.00% |
| Reduced tax rate that applies under the IP regime · Regime 2 | 0.00% |
| Reduced tax rate that applies under the IP regime · Regime 3 | 3.19% |
Effective corporate tax rates
| Measure | Year | Rate |
|---|---|---|
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 16.2% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 4.9% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 15.3% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 19.6% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 10.8% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 19.1% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 23.9% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 20.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 22.0% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 19.0% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 18.0% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 22.4% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 21.2% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 21.6% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 20.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 20.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 35.1% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 23.5% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 28.1% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 17.2% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 13.5% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 31.8% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 21.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 24.4% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 16.9% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 10.9% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 9.4% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 8.6% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 8.9% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 8.2% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 7.9% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 4.0% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 3.6% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 3.7% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 3.5% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 3.3% |
OECD Corporate Tax Statistics, baseline scenario.