Curaçao traditionally has been a logistical and financial hub between Europe and Latin American markets. Whether for tax planning, asset administration or trade, it is a logical place to establish business in the event of cross border investments between the continents. The island has a long history within the Kingdom of the Netherlands and ANT has a 100+ years of history as asset administrator. 

Business to and from Latin America is booming and so is wealth creation. As an OECD white listed jurisdiction, Curaçao has invested in its legal infrastructure to make it an attractive place to do business. This goes for foreign investors as well as for those entrepreneurs that want to establish on the islands physically. At ANT we are small enough to provide tailored services yet large enough to have a presence in key markets. 

ANT Management (Curaçao) NV
ANT Management (Curaçao) NV is a leading trust & corporate services provider in Curaçao preferred by clients all over the world. Over 50 years we have operated under the Amaco brand. Operations started mid 1950’s. 

As from January 1, 2009 we present ourselves together with our colleagues in the Netherlands, Belgium, Aruba and British Virgin Islands under one brand, ANT Trust & Corporate Services. Independent, International and In-Business. 

ANT Management (Curaçao) NV employs 50 people dedicated to excel their service to all of our clients. 

We offer trust services to a wide range of clients, including among others listed companies, privately owned companies, and private persons.
 
ANT Management (Curaçao) NV has so-called "shelf" companies readily available. These shelf companies are existing NV companies incorporated to be used by clients with specific requirements. We have NV companies that are old regime legal entities, that are grandfathered until 2019. In addition we have NV companies available that qualify for the New Fiscal Framework. 

Our clients use these products and services outside their own jurisdiction for tax planning purposes, asset protection, (family) estate planning and confidentiality reasons. 

Each fiscal product has its own specific requirements. This implies timely tax planning and, as a consequence, we require our clients to obtain advice from a tax advisory firm. 

ANT Management (Curaçao) NV is supervised by the Central Bank of the Netherlands Antilles and provides trust services in and from the Netherlands Antilles under the responsibility of a licensed trust office. Based on those requirements, we always need specific compliance information (Knowing Your Customer) from our clients.

The Netherlands Antilles
The Netherlands Antilles are a peer partner in the Kingdom of the Netherlands together with the Netherlands and Aruba. The Netherlands Antilles comprises of 5 islands in the Caribbean Sea, Curaçao, Bonaire, Saba, St. Eustatia and St Maarten. 
Curaçao offers a stable political climate, the legal system is ultimately governed by the Supreme Court in The Hague, the Netherlands. 

Furthermore Curaçao offers a strategic central location between North and South America and Europe, many of the languages in the world are widely spoken on the island, English, Spanish, Dutch and Portuguese are among them. 

There is a modern infrastructure, an USD pegged currency (ANG), a flexible legal system, a favorable tax climate and a well developed service industry. Major international banks are located on the island as well as major international auditors, tax advisors and lawyers. 
In 2001 the Netherlands Antilles was removed from the black list of the Organization for Economic Co-operation and Development (OECD). The blacklist consists of jurisdictions that the OECD considers to be engaged in what it considers harmful tax competition. 
The Netherlands Antilles time zone is four hours behind Greenwich Mean Time (GMT). 

Managed Entanglement 
Under management of the Netherlands, the Netherlands Antilles is currently in the process of entanglement into two separate and independent countries within the Kingdom of the Netherlands, namely Curaçao and St. Maarten. The other three islands will become a public body within the Netherlands because of their small size. The entanglement is to a very large extent paid for by the Netherlands. Curaçao will receive a very good starting position in the new setting. The Netherlands has enforced certain budgetary controls over government finance, which will have an even more stabilizing effect on the island.

The services we offer to our clients include:
Domiciliation services:
Providing the registered address for legal entities;
Providing office space;Maintaining corporate files;
Checking and on-forwarding of correspondence;

Management services:
Providing resident corporate directors, individual directors, proxy holders or other officers for legal entities;
Day to day management activities, such as correspondence with counsel, banks and authorities in the various jurisdictions;
Supervising matters relating to registrations with the Trade Register at the Chamber of Commerce;
Organizing and preparing minutes of general meetings of shareholders and board meetings;
Providing trustee services;

Legal services:
Providing legal advice in liaison with legal and tax advisors;
Arranging for the incorporation of legal entities;
Preparing legal documents;
Coordinating legal opinions and international transactions, including registering at a foreign stock exchange or in a ship’s register;

Accounting and Administration services:
Bookkeeping;
Preparing interim and annual financial statement according to Dutch GAAP, US GAAP or International Financial Reporting Standards;
Cash management and administration of bank accounts;
Payroll administration and re-invoicing;
Compliance with Netherlands Antilles Central Bank requirements;Assistance in preparing and filing (capital) tax returns;

Custodian services:
Acting as nominee shareholder;
Safe-keeping of stock or bond certificates and other documents of value in a separate ANT related company not involved in commercial transactions;
Applying and holding of Domain Names;

Escrow services:
Acting as a middleman in confidential transactions.

Holding Companies
A holding company is a company that maintains investments in other companies. Holding companies allow the reduction of risk for the owners and can allow the ownership and control of a number of different companies. 

As from January 1, 2001 the New Fiscal Framework ("the NFF") came into force in the Netherlands Antilles. The NFF is a modern well advanced tax system similar to the Dutch system, with advance tax ruling possibilities and a flat profit tax of 34,5%. 
Under Netherlands Antilles tax laws and regulations a holding company normally does not have to account for a domestic tax charge. The company financial statements only show a small loss incurred on general (headquarter) cost not charged out to group related companies. 

If all requirements are met a 100% participation exemption will apply in the Netherlands Antilles to dividends received from a subsidiary domiciled in the Netherlands. The participation exemption will be 95% for dividends received from a non-Dutch source (providing an effective tax rate of 1,725%). 

Based on the fiscal agreement between the Netherlands, Aruba and the Netherlands Antilles there is an 8.3% Dutch withholding tax applicable on dividend from a Dutch legal entity to a N.V. company. However based on appropriate and timely tax planning there are alternatives on hand to reduce this Dutch withholding tax to 0%. Tax advice is required in such cases. 

The Netherlands Antilles does not impose taxes on capital gains derived from the sale of an investment. 
There are two very similar options regarding the legal form of a holding company. The Netherlands Antilles Naamloze Vennootschap (NANV) and the Netherlands Antilles Besloten Vennootschap (NABV). Both are limited liability companies, but the NANV is used by public and privately held businesses whereas the NABV is only used by privately held businesses.

Download the PDF for more information about the Holding Companies

Download the PDF for more information about Aircraft registration

Finance Companies
A finance company is a company that borrows money from third parties or group related companies and lends the money received on to other third parties or group related companies. It usually refers to a company which only purpose is borrowing money and lending it on, leaving a spread in the finance company. 

Under Netherlands Antilles tax laws and regulations a finance company only has to account for a tax charge on a small margin of the interest spread (the margin between interest income and interest expense) of the company. 

Netherlands Antilles companies which provide financing for other companies need a license from the central bank; but such a company established as part of a group financing structure can qualify as a 'Concern-Financing Corporation' which does not require a license if:it receives at least 90% of its funding from the group, and any bearer bonds it issues are limited to institutional investors; orits loans are only to group companies, and the parent company of the group has provided a guarantee to the central bank to cover its external borrowing.There are two very similar options regarding the legal form of a finance company. The Netherlands Antilles Naamloze Vennootschap (NANV) and the Netherlands Antilles Besloten Vennootschap (NABV). Both are limited liability companies, but the NANV can be used by public and privately held businesses whereas the NABV is only used by privately held businesses. In respect of the NABV it is also possible to apply for a tax exempt status, meaning no income tax will become due in the Netherlands Antilles.

Download the PDF for more information about the Finance Companies

Royalties
A royalty company is a company that operates the licensing of Intellectual Property rights (IP). A royalty company acquires or develops the IP rights (either trademarks, patents or copyrights) and contracts third parties or group related companies to operate the IP right in a certain part of the world. 

The Netherlands Antilles have signed the Madrid protocol. The Madrid protocol provides a mechanism for obtaining trademark protection in many countries around the world, which is more effective than seeking protection separately in each individual country or jurisdiction of interest. The Netherlands Antilles is the only low tax jurisdiction providing the Madrid protocol protection of IP rights. 

Under Netherlands Antilles tax laws and regulations a royalty company only has to account for a tax charge on a small margin of the royalty income of the NV company. An alternative structure would be that the IP rights are owned by a Private Foundation and risk-free sub-licensed to a NABV (private limited liability) company that can apply for a cost-plus ruling, resulting in minimal tax charges. 
When using an intermediate subsidiary domiciled in the Netherlands in a Netherlands Antilles royalty structure it is also possible to use the extensive treaty network of the Netherlands. This can result in a very tax efficient royalty structure.

Download the PDF for more information about Royalties


Offshore Banking
Offshore banking companies are companies that operate a bank located in the low tax jurisdiction of the Netherlands Antilles, thus providing financial and legal advantages. These advantages typically include:

greater privacy;
low taxation;
easy access to deposits (at least in terms of regulation);
protection against local political or financial instability.

Banks and other financial institutions in the Netherlands Antilles are licensed by the Central Bank of the Netherlands Antilles. Offshore banks are known as International Credit Institutions and are exempt from foreign exchange controls. An offshore bank can operate either as a Netherlands Antilles limited company (NV) or as a branch. 

Old regime NV companies (see New Fiscal Framework (NFF)) can obtain tax rulings that lead to tax rates of 2.4% - 3%. NFF NV companies can obtain tax rulings based on cost plus rulings under certain conditions that can lead to even further reductions of the tax rate or the taxable amount.

Download the PDF for more information about Offshore banking


Mutual Funds
A mutual fund is a professionally managed type of collective investment scheme that pools money from many investors and invests it in stocks, bonds, short-term money market instruments, and/or other securities. The mutual fund will have a fund manager that trades the pooled money on a regular basis. 

There are two possibilities to structure a mutual fund in the Netherlands Antilles. Use a regular Netherlands Antilles Naamloze Vennootschap (NANV) or a Netherlands Antilles Besloten Vennootschap (NABV). 

It is possible to obtain a mutual fund tax ruling for NV’s that reduces the tax rate to 0%. 

Under certain simple conditions NABV’s can apply for a tax exempt status. The NABV has a flexible status similar to a British Virgin Islands or Cayman Island Ltd.

Download the PDF for more information about Mutual Funds


Shipping Registration
All companies, which derive profits from the operation of sea going vessels in international waters, can apply for the Tonnage Tax regime, provided that the place of effective management of the company is established in the Netherlands Antilles. 

Admissible are all vessels which the company:
Owns or co-owns (including ships chartered out on a bareboat charter basis);
Holds under a bareboat charter;
Manages on behalf of a third party; or
Operates in time or voyage charter.

A great advantage of the Netherlands Antilles Tonnage Tax is the very broad definition of t
axable profits. In principle, ‘every legitimate use of a vessel’ (outside the territorial waters of the Netherlands Antilles) is eligible for the Tonnage Tax. Thus, specialized ships like survey-, fishing-, cable-, laying- and dredging vessels, tugboats, (oil-) rigs etc. all qualify for tonnage-based taxation. Furthermore, vessels are admissible irrespective which flag they carry. 

The Tonnage Tax method allows shipping companies to calculate their profits on the basis of a specified notional profit depending on the net tonnage of the ship. The annual notional taxable profit per vessel is calculated on the basis of the following sliding scale.



If a company manages vessels on behalf of third parties, the fixed taxable profit per net ton should amount to 1/10th of the amounts mentioned above. The resulting notional taxable profit should be taxed against the Netherlands Antilles profit tax rate of 34.5%; with a minimum tax liability of USD 562 (USD 281 for management companies). 

The Netherlands Antilles company may distribute dividends to shareholders anywhere in the world free of any withholding tax. In most countries these dividends will, based on the participation exemption, be exempt from further taxation.

Download the PDF for more information about Shipping Registration


Trading
There are two types of legal entities in the Netherlands Antilles that are used in international trading activities, the Netherlands Antilles Naamloze Vennootschap (NV) and the Netherlands Antilles Besloten Vennootschap, both with a re-invoicing operation utilizing a cost plus ruling. 

The main pre-assumptions to be able to obtain a cost plus ruling are that the re-invoicing involves no significant risks to the company and that profit margins are not significant. 

A cost plus ruling leads to minimal taxable profits that are calculated against the Netherlands Antilles tax rate of 34,5%.

Download the PDF for more information about Trading
 

E-Zone Business
When certain conditions are met a tax rate of 2% is applied. The E-Zone Business will be run using an E-Zone Netherlands Antilles Naamloze Vennootschap (E-Zone NV), which is a limited liability company. The profits in the E-Zone company will not be taxed in a Dutch parent company. 

It is also possible to establish a branch office of a Dutch entity in the E-Zone and take advantage of all Dutch tax treaties. A tax ruling has to be requested and granted to obtain the status of E-Zone company established in a designated E-Zone location. 
There are some common requirements and restrictions as to which activities and which type of companies are allowed in the E-Zone.

Download the PDF for more information about the E-zone facility


Private Foundations
A Private Foundation is an excellent instrument in respect of asset maintenance, asset protection, deferral of income (i.e. pension), minimization of wealth taxation, the preservation of family assets and/or estate planning. 

The Private Foundation under Curaçao law is a truly separate legal entity. As a consequence, assets are separated and safeguarded from other individual’s wealth components in a legal entity and the founder has lost control over the assets contributed to the Private Foundation. Management of the Private Foundation is responsible for the maintenance and the distribution of the assets in line with the objectives of the founder. 

In Curaçao a Private Foundation pays no taxation on its income and there is no withholding tax on distributions made in Curaçao. However distributions may be taxed in the jurisdiction of the receiving party.

Download the PDF for more information about Private Foundation