• Service: Tax, Global Mobility Services, International Tax
  • Type: Regulatory update
  • Date: 12/17/2013

Netherlands - Proposed tax agreement with Curaçao 

December 17:  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 (TRK) currently 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
  • Gift and inheritance provisions

The current TRK will, in principle, continue to apply with respect to the relationship between the Netherlands and Aruba and Saint-Maarten. However, it is reported that the Netherlands is also preparing a new system of taxation with these jurisdictions.

Read a December 2013 report prepared by the KPMG member firm in the Netherlands: Main features new tax regulation between the Netherlands and Curaçao

©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International.

KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.

The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

Direct comments, including requests for subscriptions, to
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.


Share this

Share this


Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)

Already a Subscriber? Login

Not a member? Subscribe now