||Since 1939, the Netherlands Antilles has acted
as an international financial center, and Curaçao has become
one of the preferred locations in the Caribbean for international
tax-planning and financial transactions, with a legal system based
on civil law and similar to the legal structure in the Netherlands.
Curaçao is known for its stable political and legal climate,
superior business infrastructure and for its flexibility, professionalism
and confidentiality. Curaçao's law does not require statutory
provisions with regard to the nationality of registrars, transfer
agents, investment managers and paying agents, allowing for a great
degree of flexibility in the structuring of offshore structures, including
Curaçao is a beneficiary country under the Caribbean Basin
Economic Recovery Expansion Act (Caribbean Basin Initiative II of
1990) of the United States. The most important provision of the CBI
II is the permanent extension of the duty free treatment towards most
goods produced in a CBI country.
To qualify for duty free treatment a product should:
directly from Curaçao into US customs territory
Meet the 35%
local value added requirement: only direct processing costs in one
or more CBI countries are considered to be value added (US origin
materials may be counted toward 15 percentage points of the 35, leaving
20 percent of the value to be added in Curaçao); and
the substantial transformation requirement: the final product must
be new and different from the foreign materials used in its manufacture.
On January 1, 1991 a new tax treaty came into force between Norway
and the Netherlands Antilles. Under the new treaty, withholding tax
on dividends in Norway is reduced from 25% to 15% if paid to a Netherlands
Antilles company which is the beneficial owner and holds a participation
in the Norwegian company of less than 25%. The withholding tax on
dividends in Norway is reduced from 25% to 5% if the Netherlands Antilles
company holds more than 25% of the shares of the Norwegian company.
This treaty also contains a limitation of benefits provision along
the lines of the OECD Model treaty.