New bilateral rules for the avoidance of double taxation between the Netherlands—including Dutch jurisdictions located in the Caribbean—and Curaçao were announced and presented on 10 June 2014 to the Dutch parliament for approval. It is expected that the new amendments will come in force on 1 January 2015.
The new rules envisage an exemption from withholding tax on dividends paid to certain qualifying companies that own at least 10% of the share capital in the subsidiary (currently 8,3% withholding tax is levied). Moreover, companies that meet the 10% shareholding test but cannot be considered a qualifying company, may still benefit from the dividend withholding tax exemption if the company conducts an active business and the dividend received is derived in connection with these active business activities.