The new 3.6% offshore N.V.

The new 3.6% offshore N.V.

This new 3.6% offshore N.V. was designed by the Curacao government to offer an attractive alternative to low tax E-zone entities. This arrangement is called an “export facility”. This business entity comes with an average tax burden of 3.6%, calculated by charging 25% tax over 5% of the profit and 2.5% over the remaining 95% profit.

The Curacao government intends to offer offshore-like facilities to businesses that mainly target foreign markets. Businesses that offer their products and services locally, can apply for this facility as well.

  • 90% of profit needs to come from foreign markets.
  • Benefits gained from “business participation”, like dividends, are disregarded.
  • Business capital and business activities need to show a healthy balance.
  • >Both locally residing and foreign shareholders are permitted.

Substance Requirement

  • The business needs to be established in Curacao.
  • 50% of the executives need to reside in Curacao. This can be arranged by hiring a trust office to fulfill the role of locally residing administrator.
  • The administration is proven to have ample expertise in the industry.
  • Qualified staff is hired.
  • Executive decisions are made within Curacao.
  • The main bank accounts are held in Curacao.
  • The business administration is held in Curacao.
  • The business is not allowed to be residing in another country.


The following industries are likely to qualify for the Curacao Export Facility

  • import and export of goods;
  • international trade, ecommerce, ICT services, web shops;
  • web development, web hosting, online gaming;
  • service providers like call centers, document management services, virtual assistant offices etc.  offering their services to foreign markets.
  • international storage services;
  • business offering or managing credits, royalties, licences and copyrights,
  • holding and cooperation activities;
  • real estate businesses;