1. What is the single most important advantage your jurisdiction provides for Chinese clients?
Curaçao is part of the Kingdom of the Netherlands, so it is a very transparent jurisdiction with a modern tax code that is similar to the Dutch tax code. Curaçao is not only a logistical gateway to Latin America with its natural harbor – with one of the largest container terminals in the Caribbean, a refinery and a large modern shipyard – but it can be considered a financial gateway to Latin America too. Curaçaohas an excellent financial sector, extremely favorable tax trading regimes, and modern holding and investment regimes.
2. What is your jurisdiction’s unique selling point in setting up offshore companies for Chinese clients?
Tax considerations:
- Holding regime with participation exemption that exempts dividends received from subsidiaries and capital gains realized with the alienation of shares in the subsidiary, provided certain conditions are met;
- Favorable trading regime: Economic zone (2%) or export facility rules (approx. 3%). The export facility rules can also be applied to financing, banking and licensing;
- Tax exempt regime for financial activities, investment in shares bonds, deposits and license activities;
- Access to the Dutch treaty network through our tax arrangement with the Netherlands;
- Access to the Spanish treaty network in combination with Spanish intermediary holdings;
- Access to the Norwegian tax treaty network
- Excellent expat facilities
- Excellent potential for asset protection, maintaining family wealth, and family offices
Non-tax related considerations:
- As a part of the Kingdom of the Netherlands, Curaçao is party to 90 Bilateral Investment Treaties that provide investment protection against, amongst others, expropriation;
- Residents are multi lingual, with most speaking Dutch, English or Spanish.
- Large Chinese community
3. Do you agree that as the industry comes under increasing regulatory pressure, Chinese business will gravitate to jurisdictions that are perceived as more transparent?
Yes, Chinese business will have to adapt to this, and they must realize that if they do business in multiple countries, they would bebetter off doingso from transparent jurisdictions. Many Latin American countries, such as Colombia, Venezuela, Argentina and Brazil consider jurisdictions such as Anguilla, BVI and the Cayman Islands as black-listed, which makes it more difficult to invest through such countries.I am convinced that Chinese entrepreneurs will recognize that establishing their businesses in transparent offshore structures is increasingly important. It is not the zero tax ratethat is important –it is the substance and presence that you have in a jurisdiction that becomes more and more important.
4. Opening up a bank account for newly set-up companies has been a challenge for some jurisdictions in the past few years. Is this the casein your jurisdiction? How quickly can a company in your jurisdiction have their bank account set up?
Within 6-8 weeks
5. If you could describe the incorporation industry as it relates to China in one word, what would that be?
Underestimated (by the Chinese).
Chinese entrepreneurs have not yet found their way to Curaçao, despite the good efforts of the Chinese consul in Curaçao.
Source: Steevensz|Beckers Tax lawyers
