WILLEMSTAD - The governments of Curaçao and Suriname have finalized a landmark tax treaty designed to prevent double taxation and combat tax evasion and avoidance between the two countries. The agreement, signed on July 1, 2024, in Willemstad, marks a major step in strengthening economic ties and promoting cross-border investment between the Caribbean neighbors.
According to the explanatory memorandum accompanying the treaty, the new accord outlines clear rules on which country has the right to tax income and assets of individuals and companies operating across both jurisdictions. It also establishes a legal framework for cooperation, including the exchange of tax information, administrative assistance, and mutual debt collection support.
Negotiations Restarted After 15 Years
Negotiations for a tax treaty between the two nations first began in 2008 but stalled without result. Talks were revived in 2023, following a meeting between Curaçao’s then-Minister of Finance Javier Silvania and Suriname’s Minister of Finance Armand Achaibersing. Technical negotiations took place in Paramaribo in April 2024, where both sides agreed on the final text.
The treaty aligns with the Curaçao Fiscal Treaty Policy 2023 (CFV 2023), which seeks to expand Curaçao’s international tax network, enhance transparency, and attract sustainable investment. It follows both the OECD Model Convention (2017) and the UN Model Convention (2021), ensuring compliance with global standards against Base Erosion and Profit Shifting (BEPS).
Key Features of the Treaty
The Curaçao–Suriname Tax Treaty includes provisions to:
Avoid double taxation on income and capital gains by determining which country has taxing rights.
Prevent tax evasion and treaty abuse through clear anti-abuse clauses and exchange-of-information measures.
Facilitate investment and trade by providing certainty to businesses operating between both countries.
Provide relief mechanisms to resolve tax disputes and ensure fair treatment for residents and companies.
It specifies that dividends, interest, and royalties will primarily be taxed in the recipient’s country of residence, except under specific conditions. The treaty also contains special rules for pensions, government services, students, and artists, ensuring clarity for individuals with cross-border income.
Fiscal Neutrality Expected
The government of Curaçao expects the budgetary impact of the treaty to be neutral, as it primarily aims to eliminate double taxation rather than reduce tax revenue. Both countries anticipate that the agreement will stimulate trade and investment, while supporting economic modernization and financial cooperation.
Regional Integration
Officials noted that the treaty fits within Curaçao’s broader goal of becoming a regional investment hub for the Caribbean and Latin America. “This agreement reflects Curaçao’s open stance toward fiscal cooperation and its commitment to high international standards,” the explanatory note emphasizes.
The treaty, officially titled “Convention Between the Kingdom of the Netherlands (for Curaçao) and the Republic of Suriname for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital,” will enter into force after ratification by both countries’ parliaments.
Once implemented, the Curaçao–Suriname tax treaty is expected to enhance legal certainty, reduce administrative burdens, and promote fair taxation, marking a new chapter in economic relations between the two nations.
