Important changes for Curaçao Investment Companies, Special Purpose Funds and Transparent Companies

Important changes for Curaçao Investment Companies, Special Purpose Funds and Transparent Companies

Starting in May 2024, the process for being taxed as a Curaçao Investment Company (CIC) or a Special Purpose Asset (SPA) has been updated. Instead of submitting a request to the Tax Inspector for CIC or SPA designation, entities must now elect to be treated as a CIC or SPA annually in their profit tax return. They must confirm that they have met all the requirements throughout the fiscal year to qualify for the CIC (0% profit tax rate) or SPA (10% profit tax rate) status. Therefore, submitting a ruling request is no longer necessary.

Additionally, a transparent company (TC) will no longer automatically receive TC status if the Tax Inspector fails to issue a decision within two months of a ruling request. From May 2024 onwards, the TC status will only apply once the Tax Inspector has made a decision. Until then, the entity will be subject to profit tax and must file profit tax returns. The rules for transparent (flow-through) private foundations and trusts remain unchanged.

If you have any questions about these requirements or need help with your profit tax return, our team of expert advisors is available to assist you. Please feel free to contact us for more information and personalized guidance.