Aruba’s tax jurisdiction includes facilities that can be used for structuring a wide range of activities, such as holding company, financing, and investment operations. For example, it is possible to opt for ‘tax transparency’: the company is ignored for tax purposes and all assets and income are allocated to the shareholder. If no permanent establishment is set up in Aruba, as is generally the case with holding company, financing, and investment operations, the foreign shareholder of a transparent company is not subject to Aruban taxation.
In addition, Aruba Exempt Companies and limited liability companies that conduct holding company, financing, or investment operations are eligible for exemption from both Aruban profits tax and dividend withholding tax if they satisfy certain conditions.
Curaçao’s tax law regime also offers possibilities for international structuring, including the possibility to legally ring-fence capital in a ‘Private Foundation’ (Stichting Particulier Fonds).
Each international structure utilizing the possibilities to opt for transparency or exemption requires its own specific set-up. The Tax Partners at ATLAS will ensure that the desired tax optimization is achieved.