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5.2. Tax Consolidation / Group Treatment

Resident companies with wholly owned resident subsidiaries can file consolidated income tax return provided that the subsidiaries are organized in the Netherlands, Aruba, or St. Maarten and their place of management is Curaçao..  Also if there is a non-discrimination provision of a relevant tax treaty, entities established under the laws of a tax treaty party can be consolidated provided that they are resident in Curaçao.