Curaçao: Legislation implementing BEPS recommendations | KPMG | GLOBAL
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Curaçao: Legislation implementing BEPS recommendations includes transfer pricing reporting obligations

Curaçao: Legislation implementing BEPS recommendations

Legislative measures in Curaçao have been approved for purposes of implementing parts of the base erosion and profit shifting (BEPS) recommendations or actions.


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Among the new requirements, there are three types of transfer pricing documentation for financial years beginning on or after 1 January 2018:

  • Country-by-country (CbC) reporting
  • Master file
  • Local file

The criteria for filing a CbC report, the contents of the CbC report, and the rules for notifying the tax authorities which member of a corporate group will be filing the CbC report are provided. Similarly, there are rules for the content and filing requirements with respect to the Master and Local files. 

Other BEPS-related measures include:

  • Filing requirements for private foundations
  • Amendments to permitted activities under the export regime
  • Amendments to activities for tax-exempt companies
  • Introduction of a ultimate beneficial owner register
  • Broadened definition of administrator for tax purposes
  • New civil or administrative penalties
  • A system for information exchange with other countries
  • Tax rulings or a process for agreements with the tax authorities


Read a June 2018 report [PDF 802 KB] prepared by a KPMG member firm in the Caribbean

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