1. 1 Factsheet 2015 - Some of the main features of Curaçao’s tax system oktober 2014 Some of the main features of Curaçao’s tax system Factsheet 2015 Introduction This factsheet presents a general overview of, in particular, the profit tax, VAT, personal income tax and payroll tax regimes in Curaçao. If you would like more information or have any questions about this factsheet, please contact the tax advisors at Meijburg & Co Caribbean. Profit tax Profit tax is a direct tax on income that is levied by Curaçao on, for example, legal entities such as public limited companies (NVs) and private limited liability companies (BVs). Not only legal entities resident on Curaçao are subject to this tax, but also foreign-resident legal entities that realize profits through a Curaçaon permanent establishment. Profit tax is levied on the profit less deductible expenses. The current tax rate is 25% (in 2016: 22%). Businesses that are subject to profit tax must register with the tax authorities and meet their tax return obligations. Important points for consideration Exemptions; Interestdeduction limitations; Transfer pricing; Loss set-off; Participation exemption; Fiscal unity; Liability. Turnover tax As a rule, every supplier and customer of goods and services comes into contact with turnover tax, which is charged on supplies of goods and services by businesses in Curaçao, as well as on the import of goods. Exemptions for turnover tax apply in specific situations. The general rate is 6%. There are special rates for insurance services (7%) and for luxury goods and services (9%). There is no entitlement to recover input tax, as is the case under a VAT regime. Important points for consideration Self-supply; Exemptions; Reverse charge mechanism; Business transfers; Invoicing requirements; Debt collection; Liability; Mandatory cash registration systems. Payroll tax Payroll tax is a direct tax levied on, for example, employee salaries. It is withheld from the salary by the withholding agent (usually the employer), who remits it to the tax authorities on behalf of the employees. With regard to foreign employers, it is important to assess whether there is a permanent establishment in Curaçao, as also in that case the employer is regarded as the withholding agent.

2. 2 Factsheet 2015 - Some of the main features of Curaçao’s tax system Salary is defined as everything that is earned, in whatever name or form, from current or former employment. Subject to certain conditions, a number of reimbursements/allowances do not have to be fully or partly included in the salary of an employee, for example, reimbursed car expenses, representation expenses, telephone expenses and fixed allowances. As a rule, social security contributions and employee insurance schemes have to be withheld and remitted along with the payroll tax. Payroll tax is an advance levy on personal income tax. Important points for consideration Tax return and payment obligations; Exempt salary; Tax-free expense allowances; Anonymous employees; Liability, e.g. recipients and vicarious liability; Normative salary. Personal income tax Personal income tax is levied on individuals. Residents of Curaçao are subject to personal income tax on their worldwide income, while non-residents are subject to personal income tax on the income derived from specific Curaçaon-sourced income. An individual’s place of residence is assessed on the basis of the facts and circumstances. Factors such as where the family resides, the place and term of employment and where someone is registered can all be important. Personal income tax is a tax on your income (from work or business), your owner-occupied home or other assets. Income from work and business is taxed on a graduated scale. For 2015 the tax rates range from 10.75% for taxable income up to ANG 30,000, through to 48.25% for taxable income from ANG 127,500. There are numerous deductions and tax credits available. Generally speaking, each taxpayer must file a personal income tax return for the last calendar year. Deadlines apply. Important points for consideration Investment deduction; Replacement reserve; Expense deduction limitations; Loss set-off; Qualification as a foreign taxpayer. Social security Employees that qualify as an insured person may be subject to social security contributions and/or employee insurance contributions. Specific rules apply to the situation where an employee may or may not qualify as an insured person for the purposes of social security or one of the employee insurance schemes. Exemptions apply in certain situations. Important points for consideration Various categories of insured persons; Exemptions; Exceptions; Potential double insurance obligation in cross-border situations; Tax return and payment obligations. Tax relief A wide-range of attractive tax credits is available under Curaçao’s tax system, including the expatriate rules and various tax holidays. Meijburg & Co Caribbean has separate factsheets on most of these tax credits. International The Tax Regulation for the Kingdom of the Netherlands applies to cross-border situations between Curaçao and the Netherlands. This Regulation lays down the right to tax and attempt to avoid double taxation being levied on the same income by Curaçao and the Netherlands.

3. 3 Factsheet 2015 - Some of the main features of Curaçao’s tax system The information contained in this memorandum is of a general nature and does not address the specific 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. © 2015 Meijburg & Co Caribbean, Tax Lawyers, is a Curaçao association of limited liability companies and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Contact Should you have any questions regarding this factsheet, please do not hesitate to contact us. Legal aspects In order to work in Curaçao a number of obligations must be met. Dutch citizens do not need a separate residence and work permit. Every Dutch citizen may work in Curaçao as long as they have a Statement of Legal Admission (Verklaring Toelating van Rechtswege). To request this statement a number of documents must be provided (e.g. a Statement of Good Conduct (Verklaring Omtrent het Gedrag; “VOG”). Individuals that are not Dutch citizens must hold a residence and work permit before they can work in Curaçao. In conclusion Meijburg & Co Caribbean is a knowledge organization. Our priority is the dissemination of first-rate knowledge and we invest considerable time and effort in doing this. Meijburg & Co Caribbean has a long tradition of providing professional top quality tax advice, including in the areas discussed in this factsheet. Meijburg & Co Caribbean Curaçao Emancipatie Boulevard 18 P.O. Box 3766 Willemstad, Curaçao T: +5999 732 5400 F: +5999 737 3409 Wendell Meriaan meriaan.wendell@kpmg.com Harry Canters canters.harry@kpmg.com Foe Cheong cheong.fong-mang@kpmg.com Victor Libiee libiee.victor@kpmg.com Meijburg & Co Caribbean Rotterdam Dutch Caribbean, Suriname & Cuba desk Fascinatio Boulevard 250 3065 WB, Rotterdam The Netherlands T: +31 (0)88 909 2000 F: +31 (0)88 909 2100 Jaap Roks roks.jaap@kpmg.com Paul te Boekhorst teboekhorst.paul@kpmg.com