🇨🇼 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.
4/12
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 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
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 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
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
| 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.