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9.1. Unilateral and Treaty Based Methods Available for the Elimination or Mitigation of Double Taxation

Unilateral credit for foreign taxes is generally granted; in which case, the credit for foreign tax may not exceed the Curaçao tax on the relevant income.

Below is a summary of the available methods for various income tax streams based on domestic law.

Royalty Copyright NC
Capital Gains ND
Dividends NC
Interest NC
Royalty Patent NC
Sales NC
Service Management NC
Service Technical NC
Royalty Trademark NC

The credit column shows the type of foreign tax credit granted when the receiving country receives a payment.  Four abbreviations are used for the type of foreign tax credit available:

  • NC means no credit but foreign withholding taxes can be deducted.
  • OC means ordinary credit, i.e., credit for foreign withholding taxes (e.g., withholding taxes).
  • IC means indirect credit, i.e., credit for underlying corporate taxes as well as foreign withholding taxes.
  • ND means no credit and no deduction for any foreign withholding taxes incurred.