Caribbean Tax Update No. 2026/09

26 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 Curaçao published its minimum tax ordinance, which levies only the income inclusion rule and applies retroactively from 1 January 2025. In the Caribbean Netherlands an amendment to the Tax Plan 2027 extends the excise discount on petrol, with a phase-out in 2028 and 2029. In Sint Maarten the Ministers of Finance and VROMI explained how motor vehicle tax revenue will be allocated to the Road Fund in the 2027 budget. No new tax decisions from the courts were published this week.

Sint Maarten

Sint Maarten | Motor vehicle tax, Road Fund

Road Fund to receive Cg 5 million of motor vehicle tax in 2027; full allocation of the tax to roads planned from 2028

Under the National Ordinance Road Fund of 2010 the fund is to be financed from motor vehicle tax, but the share actually allocated has fallen over the years, as the General Audit Chamber noted in its 2024 review of the allocation for 2022 to 2024. The planned conversion of the fund into a foundation from 1 January 2027 could not be built into the 2027 budget because the legal framework is not yet in place. The Minister of Finance stated that Cg 5 million of collected road tax will go to the fund in 2027, Cg 1.5 million for operations and Cg 3.5 million for road investments, within a capital budget of Cg 9 million for roads; the remaining Cg 5.5 million is to be loan-financed. From 2028 all motor vehicle tax revenue is to be directed to the Road Fund. The 2027 budget is scheduled for debate in Parliament in the first week of November.

Sint Maarten | Gambling, draft legislation

Public consultation on the draft National Gambling Ordinance runs from 26 October to 4 December 2026

The Government of Sint Maarten has opened a public consultation on the draft Kansspelenverordening, part of the gambling sector reform under the Country Package. The reform aims at a modern regulatory system with licensing, supervision and enforcement, and stronger player protection, integrity and transparency. The draft, the explanatory memorandum and supporting English-language material are available at gamblingauthority.sx/consultationLVO, and anyone may respond until 4 December 2026. Targeted stakeholder sessions are planned between 6 and 12 November 2026. After the consultation the draft goes through the formal advisory and legislative process.

Sint Maarten | Tax administration, outreach

Tax Administration gives an information session to Form 4 students of the St. Maarten Academy Vocational Business Campus

On Thursday 22 October 2026 the Sint Maarten Tax Administration visited the St. Maarten Academy Vocational Business Campus for a session with Form 4 students as part of their Life Skills programme. The session covered why taxes are levied, how income tax works, the tax obligations of businesses and the registration requirements for people who start employment or a business. Students worked through practical examples and could put their own questions.

Curaçao

Curaçao | Minimum tax, Pillar Two

Minimum Tax Ordinance 2024 published; only the income inclusion rule is levied, with retroactive effect from 1 January 2025

The Landsverordening minimumbelasting 2024 was signed on 13 October and published on 22 October 2026 (P.B. 2026, no. 231). It applies to MNE groups with consolidated revenue of at least EUR 750 million and to reporting years starting on or after 1 January 2025. Only the income inclusion rule is introduced at the 15 percent minimum rate; the chapters on a domestic top-up tax and on the UTPR are reserved without content. The return and payment are due 17 months after year-end (20 months for the transition year) and the GloBE information return or notification 15 months after year-end (18 months for the transition year), unless the parent files in a jurisdiction with a qualifying competent authority agreement. The ordinance incorporates the OECD side-by-side package and simplifications, makes all Curaçao group entities jointly and severally liable for the tax, and replaces the Cg 1.5 billion country-by-country reporting threshold in the profit tax with EUR 750 million.

Curaçao | Aviation security levy

Aviation security levy for 2027 remains USD 0.51 per departing passenger

A ministerial regulation of 9 October 2026, published on 20 October (P.B. 2026, no. 229), sets the aviation security levy for 2027 at USD 0.51 (XCG 0.91) per departing passenger, the same as in 2026. Existing exemptions continue to apply. The regulation applies to tickets sold after publication for travel in 2027 and runs from 1 January 2027 to 1 January 2028. Tickets paid before publication for flights after 1 January 2027 remain under the 2026 regulation.

Curaçao | Tax treaties, India

Curaçao and India discuss a possible tax treaty and investment agreement

On 16 October 2026 Curaçao's Minister of Finance Cooper met India's Finance Minister Nirmala Sitharaman during the IMF and World Bank Annual Meetings in Bangkok. According to the Indian Ministry of Finance they discussed a possible agreement for the avoidance of double taxation and a bilateral investment treaty, which would be concluded through the Kingdom of the Netherlands. Nothing was signed; both sides agreed to follow up. Other topics included investment in energy storage, logistics, the port, ship repair and financial services.

Aruba

Aruba | Public finances, Cft

Board of Financial Supervision urges Aruba to make choices on tourism and warns against funds financed by earmarked taxes

In a press release of 23 October 2026 the Board of Financial Supervision (CAft) calls on Aruba to decide on the future direction of tourism and to reflect that choice in the budget, the investment agenda and tax rules. Public sector debt fell to 64 percent of GDP in 2025 and the operating result remains positive. The Board warns that new funds financed by earmarked taxes could fragment government spending, welcomes the regulation of short-stay rentals, and notes that Aruba is working with the IMF on replacing the BBO with a value added tax, which would broaden the base to the informal sector.

Caribbean Netherlands

Caribbean Netherlands | Excise duty, petrol

Excise discount on petrol in the BES islands extended through 2027 and phased out in 2028 and 2029

A second memorandum of amendment to the Tax Plan 2027 (Kamerstuk 37022), received by the House of Representatives on 20 October 2026, extends the temporary excise discount on petrol, the only fuel subject to excise in the BES islands. On Bonaire the rate per litre is USD 0.2636 in 2027, USD 0.2876 in 2028 and USD 0.3186 from 2029, against USD 0.3186 in 2026. On Sint Eustatius and Saba the rates are USD 0.2008 in 2027, USD 0.2191 in 2028 and USD 0.2427 from 2029, against USD 0.2427 in 2026. The budgetary cost is estimated at EUR 1 million, all in 2028.

Bonaire | Tax administration, counter

Tax office on Bonaire moves its counter temporarily to the back of the building from 26 October

Because the counter of the Belastingdienst Caribisch Nederland at Kaya L.D. Gerharts 12 is being renovated, a temporary counter opens on 26 October 2026 at the back of the building, next to the Plenchi di Trabou entrance. Opening hours remain Monday to Friday from 08:00 to 13:00 and all services continue. No end date has been given.

Suriname

Suriname | Customs and tax legislation

Committee of rapporteurs hears customs union and business organisations on the draft General Customs Act 2026 and continues with the other tax bills

On 21 October 2026 the committee of rapporteurs for the package of tax bills held two hearings on the draft Algemene Douanewet 2026, first with the tax service staff union and the customs officers' union, then with KKF, VSB, ASFA, AKMOS, VES and the shopkeepers' and entrepreneurs' association. The customs union considers that the draft needs amendment and clarification before a plenary debate and will submit its position in writing; the business organisations stressed legal certainty and practical workability. On 23 October the committee discussed the draft Wet Belastingdienst Suriname, the implementing act for the General Administrative Law Act and the bill on tax court proceedings, which is on the agenda again on 27 October.

Kingdom and international

International | Country-by-country reporting

Ninth OECD peer review on country-by-country reporting: no recommendations for Aruba and Curaçao

On 19 October 2026 the OECD published the ninth annual peer review of the BEPS Action 13 minimum standard, covering 142 jurisdictions. Aruba (threshold AWG 1,500 million, local filing required) and Curaçao (threshold NAf 1.5 billion, no local filing) confirmed that their rules have not changed and continue to be applied effectively. Both meet all terms of reference on the domestic legal framework, exchange of information and appropriate use of reports, and receive no recommendations. Curaçao's threshold changes to EUR 750 million under its new minimum tax ordinance.

OECD releases version 2.0 of the GloBE Information Return XML Schema, applicable from 25 June 2028

On 20 October 2026 the OECD published a revised XML Schema and User Guide for the GloBE Information Return, reflecting the 2026 changes to the return after the Inclusive Framework adopted the side-by-side package, together with technical improvements. Version 1.0 of January 2025 continues to apply to exchanges until 15 June 2028; version 2.0 applies from 25 June 2028 to all exchanges, including amendments and corrections. The schema is designed for exchanges between tax administrations but may also be used for domestic filings where local law allows.

Maarten Kroeze sworn in as president of the Supreme Court of the Netherlands

Prof. M.J. Kroeze took the oath as president of the Hoge Raad before the King on 21 October 2026. He takes office on 1 November 2026, succeeding Dineke de Groot, who has been president since 2020. Kroeze has been a justice of the Supreme Court since 2016 and vice-president of the civil chamber since 2022. The Supreme Court hears cassation appeals in tax cases from Aruba, Curaçao, Sint Maarten and the Caribbean Netherlands.