Caribbean Tax Update No. 2026/08

19 October 2026

The Caribbean Tax Update is a free weekly overview of tax case law, legislation and administrative news from Sint Maarten, Curaçao, Aruba, the Caribbean Netherlands and Suriname. Each item carries a short summary and a link to the source document.

This week the Court of First Instance of Curaçao ordered the Inspector to issue a profit tax refund assessment of NAf 27,877 within two months, because the statutory six-month term had passed without a reasoned notice. Aruba temporarily lowered the excise on petrol and gas oil by Afl. 3.24 per hectolitre until the end of 2026. In Suriname the National Assembly continued its debate on the new Collection Act, and the Minister of Finance reported that the tax debt settlement scheme has yielded more than SRD 1.2 billion.

Case law | Curaçao

Curaçao | Profit tax, refund assessment

Inspector ordered to issue a profit tax refund assessment of NAf 27,877 after missing the six-month term without a reasoned notice

A company with a financial year running from July to June paid NAf 91,093 on its provisional 2023 profit tax return and filed a final return showing tax due of NAf 63,216, a refund of NAf 27,877. When the final return results in a refund, the Inspector must issue an assessment within six months, unless he informs the taxpayer in writing and with reasons that the assessment will follow later. The Court held that this notice must be given within the six-month term; otherwise the assessment must be issued in line with the return. The Inspector first gave reasons in August 2026, almost two years late and two weeks before the hearing. The Court upheld the appeal against the failure to decide on the objection, ordered the Inspector to issue the refund assessment within two months and to reimburse the court fee. The Inspector may still examine the return and issue an additional assessment later.

Read the full decision (ECLI:NL:OGEAC:2026:189)

Case law | Caribbean Netherlands

Bonaire | Tax collection, enforcement orders

Opposition to enforcement orders and attachment of a home rejected; pending tax appeal does not stop collection

The Receiver of the Belastingdienst Caribisch Nederland served two enforcement orders on a Bonaire resident, one for a personal tax debt of USD 3,947 and one for USD 89,131 owed by a construction company for which she had been held liable as director, and attached her home. The Court held that opposition to an enforcement order cannot be directed at the legality or amount of the tax debt, and that the Receiver may enforce before an objection or appeal has been decided, even though the personal debt was later reduced to nil. The reliance on the Supreme Court's preliminary ruling of 7 November 2025 failed because the director's liability had been laid down in a decision open to appeal in tax proceedings. The attachment of the home was not disproportionate, and the invoked human rights provisions were not substantiated. The opposition was dismissed.

Read the full decision (ECLI:NL:OGEABES:2026:233)

Case law | Joint Court and Supreme Court

Curaçao | Tax procedure, appeal by the Inspector

Joint Court declares the Inspector's appeal inadmissible after he failed to state grounds for almost two years

The Inspector lodged a pro forma appeal on 21 October 2024 against a judgment of the Court of First Instance of Curaçao of 23 August 2024 in a case concerning Centrale Hypotheekbank N.V. The registry asked for grounds by 3 December 2024 and sent a reminder in October 2025, each time warning that the appeal could be declared inadmissible. No grounds were submitted. On 7 September 2026 the Joint Court declared the appeal manifestly inadmissible in a simplified procedure, without an order for costs. The judgment of the Court of First Instance stands.

Read the full decision (ECLI:NL:OGHACMB:2026:289)

Case law | Netherlands

Netherlands | Income tax, Antillean foundation and N.V.

No step-up in acquisition price for shares in an Antillean N.V. received from an Antillean foundation, because the attribution stop was never actually applied

A Dutch resident had set up a foundation under Antillean law in 2005, which was the sole shareholder of an Antillean N.V. In 2021 he and the tax inspector concluded a settlement agreement providing that, for the purposes of a later dispute about the acquisition price, they would treat the 2016 attribution stop for separated private assets as applicable. The additional assessments for 2010 to 2016 were nevertheless issued without that stop. In February 2022 the foundation donated the shares to him, after which the N.V. converted about EUR 41 million of reserves into share capital and repaid it shortly before he emigrated to Portugal. The Court of Zeeland-West-Brabant held that it must apply the actual situation and is not bound by the parties' agreement to the contrary, so the condition for the step-up was not met. The assessment, based on an acquisition price of EUR 4,607, was upheld.

Read the full decision (ECLI:NL:RBZWB:2026:7240)

Sint Maarten

Sint Maarten | Tax administration, research

Tax Administration congratulates its new adviser Wim Nijdam on a doctorate about the rise in Curaçao's tax revenue

The Sint Maarten Tax Administration congratulated Wim Nijdam, who recently joined the organisation in an advisory role, on earning a Doctorate in Business Administration. He defended his thesis in Paris on 1 October 2026, at the end of a four-year programme of the Business Science Institute with iaelyon School of Management (Jean Moulin University Lyon 3). The research examines why Curaçao's tax revenue rose by more than XCG 240 million (18.2%) between 2021 and 2022, looking at economic recovery, inflation, better compliance and the clearing of administrative backlogs. The Tax Administration draws lessons for Sint Maarten on taxpayer registration, digitalisation, a review of tax incentives and taxpayer trust.

Sint Maarten | Tax administration, Receivers Office

Receivers Office partially closed on 19 October; only the Cashiers Section remained open

The Sint Maarten Tax Administration announced that the Receivers Office was partially closed on Monday 19 October 2026. Only the Cashiers Section remained open to the public. The collection officers and all other sections of the Receivers Office were closed for the day.

Curaçao

Curaçao | Wage tax, overtime pay

Deadline for requesting the wage tax exclusion of overtime pay extended from two weeks to three months

Since the youth labour participation ordinance of 2025, overtime pay up to the income limit of the Labour Regulation 2000 can be excluded from taxable wages, provided the employer asks the Inspector within two weeks after the start of the calendar year and encloses the overtime register and an estimate of overtime per employee. Many employers found that term too short. Using the hardship clause of the ordinance and after consulting the Inspector, the Minister of Finance has extended the term to three months after the start of the calendar year, with retroactive effect to 1 January 2026. The circular is dated 7 September 2026 and was published in the Landscourant of 16 October 2026; it took effect the day after publication.

Curaçao | Tax policy, SER advice

SER annual report 2025 recalls its critical advice on the tax reform, the minimum tax, fees and the property tax initiative

The Social and Economic Council presented its 2025 annual report to Prime Minister Pisas on 9 October 2026. It recalls twelve advisory opinions, including on the 2025 tax reform bill, where the SER supported reform but missed a formal tax policy framework and recommended laying down the 15 percent profit tax rate in law and analysing the burden per income group. On the 2024 minimum tax bill (Pillar Two) it asked for a country impact assessment, and on the draft on fees, precario duties and retributions for a better justification of the rates. On the initiative to amend the property tax it calculated a fall in revenue from Cg 84 million to Cg 58.8 million, and it noted that about 40 percent of taxable properties are not assessed and some Cg 235 million in property tax is outstanding.

Curaçao | Tax administration, service

Tax administration asks taxpayers to use its online contact form for digital questions

The Belastingdienst Curaçao asks taxpayers to send questions and messages through the contact form on its website, which it treats as equivalent to an e-mail. The form guides users by subject so that requests arrive complete and reach the right department directly. A valid sédula number is required; without it the request cannot be linked to the taxpayer's file and the taxpayer must visit the counter with a passport or driving licence. The counter at WTC Curaçao is open on weekdays from 08:00 to 15:00.

Aruba

Aruba | Excise duty, petrol and gas oil

Excise on petrol and gas oil temporarily lowered by Afl. 3.24 per hectolitre until 31 December 2026

Following a sharp rise in pump prices from 14 October 2026, the Council of Ministers decided on 13 October to lower the excise on imported petrol and gas oil temporarily. From 14 October to 31 December 2026 the rates are Afl. 58.1609 per hectolitre for petrol and Afl. 29.9609 per hectolitre for gas oil, instead of the regular Afl. 61.40 and Afl. 33.20 that apply since 12 August 2026. The reduction is a favourable policy of the Minister of Finance, cited as the Tijdelijk besluit accijnsverlaging oktober 2026, and anticipates an amendment of the Landsverordening accijns minerale oliën. The same Landscourant contains the new maximum retail fuel prices.

Aruba | UBO register, Economic Affairs Department

Economic Affairs Department reorganised to absorb consumer protection and the tasks arising from mandatory UBO registration

By national decree of 25 September 2026, published in the Landscourant of 16 October, the founding decree of the Directie Economische Zaken, Handel en Industrie (DEZHI) has been replaced in full. The decree notes that the department has had additional tasks since mandatory UBO registration was introduced on 1 January 2023. The Servicio na Defensa di Consumidor is abolished and its handling of individual consumer complaints and its support to the rent committee move to DEZHI. The sustainable development planning unit is renamed the National Planning unit.

Caribbean Netherlands

Bonaire | Island budget 2027, local taxes

Revised 2027 draft budget of Bonaire estimates local levies at USD 43.0 million

After the Board of Financial Supervision returned the first version, the Executive Council of Bonaire submitted a revised draft 2027 budget, balanced at USD 153.2 million, to the Island Council on 29 September 2026. Local taxes and fees are estimated at USD 43.0 million, against USD 38.2 million in the 2026 draft, including tourist tax of USD 16.5 million, motor vehicle tax of USD 6.97 million, land tax of USD 2.56 million and property tax surcharges of USD 3.28 million. The Executive Council intends to strengthen tax administration and collection and to review the levy bases. The joint standing committees discussed the draft on 13 October; the Island Council is scheduled to decide on 27 October 2026.

Caribbean Netherlands | Tax administration, annual accounts

Tax administration publishes a new form to request a three-month extension for filing annual accounts

The Belastingdienst Caribisch Nederland published an updated form on 14 October 2026 with which an individual taxpayer can request an extension for submitting annual accounts. The form asks for the CRIB number, contact details, the financial year and the reasons for the delay, and provides for an extension of three months. It replaces an earlier version.

Caribbean Netherlands | Social security, unemployment benefit

Temporary unemployment benefit for the BES islands starts on 1 January 2027; information sessions on Saba and Sint Eustatius

From 1 January 2027 employees on Bonaire, Sint Eustatius and Saba who lose their job through no fault of their own can apply for a benefit of up to three months under the Tijdelijke regeling werkloosheidsvoorziening BES, which runs until 31 December 2031 at the latest pending a permanent law. Eligibility requires work in at least 26 calendar weeks during the ten months before the last working day; civil servants are excluded. The SZW unit of the Rijksdienst Caribisch Nederland holds information sessions on Saba on 26 October, on Sint Eustatius on 28 October and on Bonaire in November 2026.

Suriname

Suriname | Tax collection, legislation

National Assembly continues debate on the Collection Act; government announces a memorandum of amendment

De Nationale Assemblée continued the public debate on the draft Invorderingswet and the Kostenwet Invordering Belastingen on 13, 15 and 16 October 2026. Under the bill the tax collector can issue an enforcement order itself when tax remains unpaid after a reminder, and use it for attachment and forced sale without a prior court judgment. Minister of Finance and Planning Adelien Wijnerman announced a memorandum of amendment covering, among other things, the reference to the tax court, payment deferral and confidentiality. Members asked for objective criteria for deferral, protection of the subsistence minimum on attachment and a cap on the collection fee of 1 percent of the tax debt, with a minimum of SRD 500. The debate was adjourned and the bills have not yet been adopted.

Suriname | Tax debt settlement

Tax debt settlement scheme provisionally yields SRD 1.25 billion, more than twice the estimate

During the debate on the collection bills on 12 October 2026, Minister Wijnerman reported that the Belastingdienst's settlement project for outstanding tax debts has provisionally yielded SRD 1,249,181,686, against an estimate of SRD 527,547,779 based on collecting 30 percent of eligible debts. The scheme started in September 2025 for six months and covered tax years 2020 to 2023; in January 2026 it was extended by three months and widened to 2024. The final result depends on running payment arrangements and on objections and applications filed shortly before the deadline. A final settlement and evaluation will follow.

Committee of rapporteurs hears the tax administration and the customs union on the draft General Customs Act 2026

On 12 October 2026 the committee of rapporteurs for the package of tax bills discussed the draft Algemene Douanewet 2026 with the Director of Taxes and her experts and with the customs officers' union. The tax administration described the draft as a framework act, with implementing rules to follow by state decree; it covers, among other things, export clearance, exemptions and border traffic. Work on the draft began in 2003. The committee will meet the union and business organisations, including KKF, VSB, ASFA and AKMOS, on 21 October 2026.

Suriname | Wage tax, child allowance

Tax-exempt child allowance doubled to SRD 250 per child per month

A state decree of 3 June 2026 (S.B. 2026 no. 47), promulgated on 9 June and made available online in October 2026, amends the Wage Tax Act so that the exempt part of child allowance rises from SRD 125 to SRD 250 per child per month. The limit of four children remains, so the monthly maximum rises from SRD 500 to SRD 1,000. The explanatory note refers to the exchange rate and the higher cost of living for families with children. The decree took effect on the day after promulgation.

Kingdom and international

International | OECD report to the G20

OECD tax report to the G20 counts about 65 jurisdictions introducing the global minimum tax and confirms Suriname's Global Forum membership

The OECD Secretary-General's tax report for the G20 finance ministers' meeting of 15 October 2026 focuses on how corporate income tax can support business dynamism. Around 65 jurisdictions have legislated or begun introducing the global minimum tax; the OECD Central Record lists 44 jurisdictions with a qualified income inclusion rule and 50 with a qualified domestic minimum top-up tax and safe harbour. Suriname joined the Global Forum in July 2026 as its 174th member, and 77 jurisdictions have committed to exchanging crypto-asset information under the CARF, with first exchanges expected in 2027. A public consultation on transfer pricing for intra-group services is planned for 9 November 2026.

Global Forum completes its first accelerator programme on cross-border assistance in the recovery of tax claims

The Global Forum Secretariat concluded the first edition of its Cross-Border Assistance in the Recovery of Tax Claims Accelerator Programme, delivered with the Belgian Federal Public Service Finance and with participation of the French Public Finances Directorate General. Over nine months 24 jurisdictions worked on the legal basis for recovery assistance, tax debt management, setting up dedicated units and handling incoming and outgoing requests, and each drew up an action plan. The programme was open to jurisdictions in Africa, Asia, the Caribbean, Europe, Latin America and the Pacific.

Kingdom | Joint Court of Justice

Sigmar Carmelia installed as president of the Joint Court of Justice

Mr S.A. Carmelia was installed on 16 October 2026 in Curaçao as the 26th president of the Joint Court of Justice of Aruba, Curaçao, Sint Maarten and of Bonaire, Sint Eustatius and Saba, which also hears tax appeals. He succeeds Mauritsz de Kort, who became Governor of Curaçao. In his speech he referred to the improved publication of judgments, court housing on Bonaire, Aruba and Sint Maarten, and the development of local legal talent.

The Caribbean Tax Update is a free weekly publication of Aalbers Private Tax Advisory. It is based on publicly available sources, in particular decisions published on rechtspraak.nl and official publications of the governments of Sint Maarten, Curaçao, Aruba, the Caribbean Netherlands and Suriname. Summaries are provided for general information only and do not constitute tax advice. No liability is accepted for any reliance on this publication.

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