Curaçao has published Ministerial Decree P.B. 2020 no. 88 on foreign profit tax regimes considered comparable to the Curaçao profit tax. This is important in relation to the subject-to-tax test for Curaçao's participation exemption for dividends received, which generally provides that a subsidiary must be subject to a nominal tax on profit at a rate of at least 10% or must be established in a jurisdiction with a tax regime comparable to that of Curaçao.
The Ministerial Decree provides that …