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13.4.3. Documentation Requirements

Standard Documentation

A documentation obligation is applicable in the SOPT, for which the OECD guidelines for Multinational Enterprises and Tax Administration need to be considered. However, the legislature has not yet issued detailed implementation guidelines.

For reporting fiscal years starting on or after 1 January 2019, MNE groups based in Aruba are required to prepare a Master file and a Local file if an annual consolidated group revenue threshold of AWG 100 million is met.

Country-by-Country (CbC) Reporting

For reporting fiscal years starting on or after 1 January 2019, Country-by-Country (CbC) reporting requirements are applicable to ultimate parent entities of multinational groups in Aruba having an annual consolidated group revenue threshold of AWG 1.5 billion in the previous year. The CbC report is required to be filed within 12 months after the end of the reporting fiscal year.

Language of Documentation

The CbC report, Master file and Local file are required to be drawn up in the Dutch or  English languages.