Taxes and Incentives

Aruba is looking to diversify the economy in the context of “sustainability and smart growth”, and has created an attractive package for investors and entrepreneurs wishing to benefit from the location, safety and security of Aruba to develop their business activities. Government policy supports investments to promote further economic diversification and enhance the quality of life.




Profit tax is due on the profit of an enterprise that carries out its business in Aruba through a local entity (e.g. a Limited Liability Company) or a permanent establishment, permanent representative or fixed property of a foreign entity. The regular profit tax rate is 28%.

The following entities are subject to profit tax:
1. An in Aruba incorporated and established:
• Limited Liability Company;
• Private Limited Liability Company;
• Limited Partnership with shares;
• Aruban exempt company;
2. A permanent establishment or permanent representative of a foreign entity.

Transfer Pricing Requirements
In case an entity or individual participates, directly or indirectly, in the management, supervision or capital of two or more entities, the conditions between these entities which are applicable to the supply of goods or the rendering of services must be at arm’s length, i.e. similar to the conditions that would have been closed with third parties. Documentation to substantiate the at arm’s length transactions should include e.g. (1) the agreement, (2) the transfer pricing method that was chosen, (3) why this method was chosen, and (4) how the fee has been determined.

Limitations in the Deduction of Payments
If payments are made to entities situated in Aruba or abroad, the transactions resulting from the payment made should be at arm’s length. Payments include all remunerations for the use of material and/or immaterial goods or rendered services such as interest, royalties, and management fees. If the transaction is deemed at arm’s length, the payments are still not tax deductible unless the Aruban company can make it credible that:
• The receiving party is not (in)directly related to the Aruba company; or
• The receiving party pays an effective tax rate of at least 15%; or
• All the shares in the receiving company are held by an entity that is (in)directly for at least 50% of the shares and voting rights, listed at a qualified Stock Exchange.

If the payment is at arm’s length, but one of the above exceptions does not apply and the receiving party is subject to taxes, than 75% of the payment could still be deducted.

A relation with the taxpayer is deemed to exist if:
1. The taxpayer has an interest of at least 1/3 in another entity; or
2. An individual or entity has an interest of at least 1/3 in the taxpayer; or
3. A third party has an interest of at least 1/3 in another entity, while this party also has an interest of at least 1/3 in the taxpayer.

Participation Exemption
If a company situated in Aruba holds shares or similar rights in another Aruban entity, the dividends received and the capital gains realized with the sale of these shares are exempt from corporate income tax. If a company situated in Aruba holds shares or similar rights in a foreign entity, the participation exemption only applies if these shares in the foreign entity are not held as an investment and the foreign entity is subject to a tax on profits.

Costs related to the participation are in principle not tax deductible. However, as of fiscal book year 2013, interest paid for the purchase of shares in an Aruban entity are tax deductible, provided that the interest is not deductible in the first two years after the purchase of the participation. In the third year and the following two years (year 4 and 5) the interest of the first two years can be deducted in three equal installments. The interest due as of the third and following years is fully deductible.

Offset of Losses
Losses generated in a year can be offset against profits generated in the following five years. Losses that remain after the five year period will evaporate. In case of an oil and gas exploration company the losses can be carried forward for a period of 20 years. In case of an Imputation Payment Company or an oil refinery there is no limit to the carry forward of losses.

Fiscal Unity
It is possible to apply for a fiscal unity between two or more Aruban entities if the parent company owns at least 99% of the shares in the subsidiaries at the beginning of the year. A fiscal unity implies that for corporate income tax purposes the subsidiaries are disregarded and all profits are allocated to the parent company.

Fiscal Incentives Companies
Gift deduction
Gifts (donations) made by companies are only tax deductible if they are made to charitable, welfare, cultural, ideological and scientific institutions with a maximum of AWG. 50,000 (USD 27,932) per fiscal book year.

Temporary investment deduction
A temporary investment deduction of annually 6% of the purchase value of a fixed asset is available to entrepreneurs and is only applicable to investments of minimum AWG. 5,000 (USD 2,793) in the year the investment is made.


Personal income tax is due on income from inter alia real estate, securities, business, employment or recurring allowance. Individuals are subject to personal income tax if they are residents of Aruba. Residency is determined by taking into account all facts and circumstances, i.e. the place where the person’s social activities are concentrated. Non-residents are only taxable for certain types of income derived from Aruban income resources. The personal income tax rate is a progressive rate with a maximum of 58.95%.


Wage Tax
Wage tax is a pre-levy to the personal income tax. Wage tax has to be withheld as soon as an employment exists. The employer is in principle the withholding agent. If it involves a foreign employer, this employer only has to withhold wage tax if the employer has a permanent establishment on Aruba. The Tax Department may however appoint a foreign employer as a withholding agent (even if there is no permanent establishment).

Wage is described as all remunerations received from a (former) employment, no matter how the remuneration is called. Excluded from wage are for example the employers’ part of the social premiums and qualifying pension premiums.

The wage tax rate is equal to the personal income tax rate and is a progressive system. Personal income tax is due starting at an income of AWG. 20,252 (USD 11,314). The maximum rate is 58.95%.

Some benefits (“fringe benefits”) provided by the employer are tax exempt or taxable against a fixed amount/rate. There are also specific rules for expatriates.

Social Security Premiums
AOV/AWW (General insurance for Old Age / Widow and Orphans)
The AOV/AWW premium is paid by employee and employer. The AOV/AWW premium amounts to 13.5%. The premium is paid by the employer (9.5%) and by the employee (4%). The aforementioned percentages are to be calculated over the premium income which is maximized at AWG. 65,052 (USD 36,342) and is only due until the employee reaches the age of 60.

General Health Insurance (AZV)
The AZV premium is paid by the employee and the employer. The AZV premium is 11.5%. The premium is paid by the employer (8.9%) and by the employee (2.6%). The aforementioned percentages are to be calculated over the premium income which is maximized at AWG. 85,000 (USD 47,486).

Sickness and Accident Insurance Premium
This premium is only paid by the employer. The percentage for sickness insurance is 2.65%. The percentage for accident insurance varies from 0.25% up to 2.5%, depending on the risk involved at the job.

Expatriate Regulation

An employee from abroad can apply for the expatriate regulation provided that certain conditions are met:
• To be considered as an expatriate the employee needs to have specific skills that are scarce on the labor market. It is assumed that the employee has these skills if his/her salary is at least AWG. 150,000 (USD 83,799);
• The expatriate needs to be in the possession of a resident and work permit;
• The expatriate can only apply for the expatriate regulation if he/she lived 5 years in another country prior to working in Aruba;
• During his/her time in Aruba the expatriate must train a local employee, so he/she can take over the specialized work when the expatriate has returned to his/her home country.

Once the aforementioned conditions are met the expatriate will enjoy the following benefits for a period of four years:
• The employer can give a tax free financial compensation to an expatriate with a maximum of AWG. 15,000 (USD 8,380) per calendar year;
• The expatriate can receive a tax free compensation of AWG. 25,000 (USD 13,966) per child, per calendar year for school tuition in Aruba and/or abroad;
• The employer can give a tax free compensation with a maximum of AWG. 2,500 (USD 1,396) monthly, for the expatriate to rent a house in Aruba;
• Contrary to the principal rule in the wage tax legislation, the wage of the expatriate will be grossed up only once, in the event the employer and employee concluded a written net salary employment agreement.

The employer has to file a written request with the tax authorities in order for the expatriate regulation to be applicable. The expatriate has to co-sign the request.


Dividend withholding tax is due upon dividend distributions from companies situated in Aruba. The tax rate is:
• 10% of the dividend distribution;
• 5% of the dividend distribution if the shares of the distributing company or the receiving company are (for at least 50% of the shares and the voting rights) directly or indirectly listed at a qualified Stock Exchange;
• 0% if the participation exemption (see profit tax) is applicable.

Dividends between countries of the Dutch Kingdom are subject to the Regulation for the Dutch Kingdom (hereinafter: the Regulation). In certain situations the Regulation reduces the rate of the dividend withholding tax from 10% to 7.5% or even 5%.

As of fiscal book year 2013 dividend distributions from special purpose companies, companies situated in the Special Zone in San Nicolas and FreeZone companies are exempt from dividend withholding tax.

Dividend distributions include, among others:
• Formal dividend distributions;
• Liquidation payment;
• Bonus shares;
• Paying back of share capital, unless strict conditions are met;
• Imputation payment.


Turnover tax (hereinafter: BBO) is due on the turnover of an entrepreneur which is realized with the delivery of goods or the rendering of services in Aruba. An entrepreneur is every person who independently carries out a business or a profession through for example a LLC, a natural person or a form of association (joint venture and partnership). Therefore, even a foreign company is an entrepreneur for BBO purposes. Goods are defined as all tangible objects and some intangibles like gas and electricity. Services are defined as all activities, which do not qualify as the delivery of goods, provided that the activities are performed for a consideration.

The BBO rate is set at 1.5%. The taxable base consists of all remunerations in kind or in cash received by the entrepreneur. If the payment is not at arm’s length or in kind, the taxable base is the fair market value of the goods delivered or the service rendered. An exception is made for own produced/manufactured products. In that case the taxable base is the cost price of the goods.

The delivery of goods or the rendering of services should be in Aruba to constitute a taxable event for the BBO. In the case that the goods are shipped or transported the place of delivery of goods is where the goods were shipped or the transportation initiated. In all other cases, the place of the delivery of goods is where the goods are at the time of the delivery. If services are rendered the place of the services is there were the entrepreneur is established or where the entrepreneur has a permanent establishment from which the services are rendered. Exceptions are made for certain services.

The turnover realized by the delivery of certain goods and the rendering of certain services are exempt from BBO. For instance, the delivery of fuel to companies whose goal is the production and delivery of water and electricity is exempt from BBO.

It is also possible to apply for a fiscal unity between two or more Aruban entities if the parent company owns at least 99% of the shares in the subsidiaries. All revenues of the subsidiaries are allocated to the parent company.


Import duties are due upon the import of goods. Primary goods are in general, subject to a zero tax rate, while higher tariffs are applicable for goods depending on their degree of luxury. Reduced import duties apply for certain green products such as:
• 2% import duties on wind turbines, solar panels and electric cars and parts;
• 12% on hybrid cars;
• 2% import duties on inverter air-conditioning with an energy efficiency ratio of ≧SEER 14,5/ EER 12/ EER 3,5; on air-conditioning with a VRF/ VSC system; on refrigerators, washing machines, industrial dishwashers with an Energy Star label; on CFL and LED lights with a Cos phi value of ≧ 0,85; and on geysers and water heaters on solar energy.


The Foreign Exchange Commission (FEC) is due when residents make a payment abroad. The FEC amounts to 1.3% over the payment abroad. In the text of the law a payment abroad is defined as:
• A payment with local currency or a payment against a florin account, whether or not by electronic transfer;
• A payment with foreign currency or a payment against a foreign currency account, whether or not by electronic transfer;
• A payment against a foreign currency account abroad or against an intercompany account with a person or entity abroad, whether or not by electronic transfer.

Insofar the payment is a result of one of the following legal transactions:
• the purchase of foreign currency or foreign exchangeable; or
• obtaining control over receivables in one or more foreign currencies; or
• an addition to an account of a non-resident of Aruba at a bank or an institution abroad.


The tourist levy is a levy payable by a non-resident guest of a hotel or other accommodation. The tourist levy amounts to 9.5% on the remuneration received for the use of a room. If an all-inclusive package is provided, 45% of the package price must be allocated to the room. If 45% of the package price exceeds USD 90.50, the tourist levy is 9.5% over 45% of the package price. If 45% of the package price is less than USD 90.50, the tourist levy is 9.5% over USD 90.50.

Timeshare guests will have to pay the 9.5% tourist levy on a fixed amount per day, which varies per type of accommodation:
• AWG. 179 (USD 100) for a studio;
• AWG. 193.95 (USD 108.35) for a one bedroom apartment;
• AWG. 223.75 (USD 125) for all other accommodations.


Gaming Tax
The gaming tax is levied on the gross revenue of the casino and amounts to 4%.

Environmental Levy
As of August 1st, 2013 a tourist staying in a timeshare resort, a hotel, or accommodation should pay an environmental levy amounting to:
• USD 3 per night per occupied room for a stay in transient hotels or accommodation;
• USD 10 per stay for a studio in a timeshare resort;
• USD 15 per stay for a one-bedroom apartment in a timeshare resort;
• USD 25 per stay for any other type of room in a timeshare resort.

Travel Promotion Levy
On each travelling ticket to Aruba a travel promotion levy of USD 10 is levied.

Inheritance and Gift Tax
The inheritance and gift tax rate is progressive and ranges from 2% to 24%, depending on the degree of kinship and the value obtained. Local real property obtained as an heir or legatee or as a gift from a non-resident is taxed at 8%

Transfer Tax
Upon the transfer of real estate a transfer tax is levied on the fair market value of the real estate transferred. The transfer tax rate amounts to 3% for the first AWG. 250,000 (USD 139,665) and 6% over every amount exceeding AWG. 250,000.

Land Tax
The land tax rate amounts to 0.4% of the registered value of the real estate taking a general exemption of AWG. 60,000 (USD 33,520) into account.

Incentives and Agreements


Aruba Exempt Company
The Aruba exempt company could be exempt from corporate income tax, provided that it has the following activities:
• Holding activities;
• Licensing activities;
• Financing activities, but not acting as a financial institution;
• Investment activities, except for real estate.

Transparent Company
Entities may opt for treatment as a partnership, i.e. become a transparent company for tax purposes. This will only result in taxation of corporate income tax on Aruba if the shareholder abroad has a taxable presence (a permanent establishment or permanent representative) on Aruba. In that situation the profit, in as far as the profit can be allocated to Aruba, is taxable on Aruba against the 28% corporate income tax rate. The transparent company is however not subject to the dividend withholding tax due to its transparency.

Imputation Payment Company / Special Purpose Company
The Imputation Payment Company regime entailed that part of the corporate income tax paid would be remitted to its shareholders in the form of an imputation payment. The Imputation Payment Company regime was open to all enterprises conducting specified activities such as hotel, financing, licensing or investment activities. As of the fiscal book year 2013 the Imputation Payment Company regime has been modified and it will eventually cease to exist.

In place thereof a Special Purpose Company is designed. If a company has activities as published per decree AB 2005 nr. 90, or the activities as listed below it can be eligible for a profit tax rate of 10% and an exemption of dividend withholding tax. A request should be filed with the tax authorities:
• Sustainable activities such as green energy projects, sustainable tourism other projects on sustainability with exemption of hotels (for hotels another regime is applicable);
• Activities stimulating the knowledge economy;
• Scientific activities.

In the event a hotel can be categorized in one of the following categories and certain requirements are met it can claim an exemption from dividend withholding tax and the following profit tax rate will be applicable:

I RevPar USD 185 10%
II RevPar USD 175 12%
III RevPar USD 160 15%
IV 4 Diamond status 12%

In order for hotels to qualify for this regime the following requirements should be met:
1. The hotel should be in the possession of an earth check certificate or a similar certificate at the latest January 1, 2015. If the hotel can proof that it has started the process of obtaining such a certificate it is assumed that this requirement is met. The certificate at the lowest possible level will suffice.
2. The hotel should invest a certain amount each year in the Aruban community in order to make Aruba more sustainable.

I Hotels > 100 rooms AWG. 240.000 Hotels < 100 rooms AWG. 120.000
II Hotels > 100 rooms AWG. 165.000 Hotels < 100 rooms AWG. 75.000
III Hotels > 100 rooms AWG. 90.000 Hotels < 100 rooms AWG. 40.000
IV Hotels > 100 rooms AWG. 165.000 Hotels < 100 rooms AWG. 70.000
One third of the investment should be allocated in green energy projects another third in education and the last third in the purchase of local products. The investment can be deducted from the profit of the company.
Special Zone San Nicolas
As of July 1st 2013 by means of a favorable policy the government of Aruba introduced a new zone called the Special Zone in San Nicolas to stimulate the economy of San Nicolas for a period of at least 10 years. As of this date entities (e.g. LLC VBA Aruba Exempt Company Foundation etc.) that apply for the Special Zone status can enjoy certain tax benefits provided that certain conditions are met:
1. For local activities the tax benefits are as follows:
• 15% profit tax;
• 10% profit tax for hotels;
• 2% profit tax for qualifying activities such as projects concerning sustainability green energy knowledge and sustainable agriculture however 75% of the products and or services should be sold on the internal market;
• Exemption dividend withholding tax;
• 50% discount on the land tax for a period of 5 years;
• Investors can request the Minister responsible for infrastructure for a lower value on the land;
• Special package for expatriates;
2. For export orientated activities the following additional tax benefits will apply:
• 2% profit tax for captives;
• 10% profit tax if export is more than 75%;
• Exemption for BBO for exported products;
• Exemption for BBO for exported services;
• Exemption for foreign exchange tax as long as the payments are connected with the export of services and products;
3. An additional investment allowance of 10% on all investments (local as well as foreign investments). For companies that make use of the transitional arrangement for companies that were already established in San Nicolas at the beginning of 2013 a minimum investment of AWG. 50 000 (USD 27 933) is required in order for the additional investment allowance to be applicable;
A permit for the Special Zone can be obtained for AWG. 500 (USD 279) at the Aruba Financial center (here after AFC).
The requirements for approval of a business within the San Nicolas Special Zone are:
1. Investment: For retail industry services and small industrial companies hotels with less than 100 rooms restaurants and agriculture a minimum investment of AWG. 150 000 (USD 83 799) is required. For heavy industry and tourist activities such as large hotels (100 or more rooms) the minimum investment is AWG. 1 000 000 (USD 558 659). A lease contract can be seen as an investment. Employee costs and investments in vehicles do not qualify as an investment for the purpose of the Special Zone regime.
2. Employment: The business must employ at least three employees (3 FTE where 1 FTE = 40 working hours per week) if its revenue is less than AWG. 1 000 000. For every additional AWG. 1 000 000 the business must employ three additional employees. For heavy industry and the tourism sector a minimum of nine employees should be employed.
3. Contribution to the San Nicolas Business Association: The San Nicolas Business Association (SNBA) has the responsibility to keep the Special Zone clean and safe. Therefore Special Zone companies need to pay a yearly contribution of AWG. 1 200 (USD 670 for a company with less than nine employees) and AWG. 2 400 (USD 1 340 for companies with nine employees or more).
4. Additional requirements for hotels: The hotel should be in the possession or at least prove that it has started the process of acquiring an earth check certificate or a similar certificate (a certificate of the lowest category). The hotel should invest yearly in the community of San Nicolas and its near surroundings. For hotels with 100 rooms or more the amount is at least AWG. 90 000 (USD 50 279) and for hotels with less than 100 rooms the investment amount is AWG. 45 000 (USD 25 140). One third of the investment should be allocated in green energy projects another third in education and the last third in the purchase of local products. The investment is fully deductible from the profit of the company.
FreeZone Aruba
The free zone company is a company that focuses on export of goods and/or services (except for financial services) through a designated area in Aruba. The corporate income tax rate is set at 2% on the profit generated with its export activities. As of July 1st 2013 the Free zone has been modernized as a result of which it has become very suitable as a hub between Europe and South America and also making it more attractive. The main features of the modernized FreeZone Aruba are:
1. Clarification on the definition of services. Activities as consultancy courses and certification can now take place in the FreeZone;
2. A free zone company (services only) can be located anywhere on the island;
3. The main principle is that no more than 25% of the services and or products may be sold on the internal market;
4. In certain situations (activities in the field of sustainability and activities suitable for the gateway concept) the ratio between export and internal market can be 50/50%. This will apply for the following activities: a. sustainable energy b. sustainable food production c. medical tourism d. sustainable means of transportation e. maintenance and repairs. A request can be filed with the Minister of Finance and the Minister of Economic Affairs;
5. In some special cases the Minister of Finance together with the Minister of Economic Affairs can give permission to deviate from the 50/50% ratio so more products or services can be sold on the internal market. For instance for activities that will help lower the costs for utilities activities that will enhance healthcare waste management and the reduction of food prices. It should be clear that these activities should have an added value for the Aruban community otherwise no permission will be granted. In these special cases a profit tax of 2% will be due on the profit that derives from sales to the internal market. Also an exemption of import duties will be applicable.
6. As of January 1 2013 the FreeZone Facility Charge (FFC) will be 0.75% of the turnover. The higher the turnover the less a company will pay. See table below.
0-100.000.000 0.75%
100.000.001- 0.20%
150.000.001-200.000.000 0.10%
200.000l001 of hoger 0.01%

7. Exemption for dividend withholding tax;
8. The special package for expatriates is applicable.


Thus far, Aruba has no double taxation treaties. For the prevention of double taxation within the Dutch Kingdom Aruba concluded a Tax Regulation for the Kingdom of the Netherlands. Furthermore, Aruba has several (approximately 25) Tax Information Exchange Agreements.


Oil refineries and oil terminals are subject to a tax rate of 12%. However, under certain conditions, oil refineries or terminals whose shares are all held directly or indirectly by a company listed on a stock exchange recognized by the Minister, are subject to a 7% CIT rate. Under this regime losses may be carried forward unlimitedly. Moreover a 0% dividend tax rate applies to distributions from profits from the operation of an oil refinery or terminal.


Aruba is a category 1 country for the registration of aircraft and very favorable for companies that lease aircraft to third parties as well as for financiers. There are high standards in place which operators must comply with when it comes to evaluating aircraft airworthiness, and flight crew. When an aircraft is registered under the Aruban nationality it may land virtually anywhere. This is why the registration of aircraft under Aruban nationality is very favorable.

In addition, Aruba has a favorable tax regime in place for this type of business. The Aruba Exempt Corporation (A.V.V.) and/or the transparent company are commonly used as special purpose vehicles for the ownership or lease of the aircraft and subsequently the registration in the Aruban Nationality Register. For further information please visit


In general, Aruba supports a noninterventionist trade policy. Therefore, trade can be performed with countries globally. In this sense Aruba has some trade agreements that should also make it easier to export your product or offer your services. These agreements may ensure that your company has a competitive advantage.


Aruba is a beneficiary of the Caribbean Basin Initiative (CBI). The CBI is a trade program initially launched in 1983 intended to facilitate the economic development and export diversification of the Caribbean Basin countries. Through the Caribbean Basin Economic Recovery Act (CBERA) of 1983 (amended in 1990) and the Caribbean Basin Trade Partnership Act of 2000 (CBTPA), Aruba and beneficiary countries derive duty free entry to the United States for a broad range of products. Moreover, effective October 2000, apparel made in the CBI designated countries from U.S. yarns and fabrics receive NAFTA equivalent treatment and enter the United States free of quota and duty.

Previously excluded products such as certain footwear, prepared or preserved tuna, petroleum or petroleum products, certain watches and watch parts, and certain handbags, luggage, flat goods, work gloves and leather apparel receive NAFTA equivalent treatment.


Aruba as an Overseas Country Territory is eligible for the benefits of the trade paragraph of the Overseas Association Decision (OAD). The OAD offers Aruba preferential access of products to the market of the European Union (EU) once those products comply with the rules of origin.


Since adaptations to the schedules for goods and services need to be refined, Aruba is currently not an independent member of the World Trade Organization. The membership of the Kingdom of the Netherlands enables Aruba to participate in WTO deliberations but does not grant the island independent voting rights. Nonetheless, Aruba is signatory to the plurilateral agreement in the WTO that may be of benefit to companies offering goods, services and construction services to government buyers. This is the Government Procurement Act (GPA). The GPA makes markets of thousands of worldwide government entities accessible to Aruban suppliers of goods, services and construction services. The United States and Canada are both signatories of the WTO’s Government Procurement Agreement as well, which gives Aruban suppliers the opportunity to participate in American and Canadian procurement markets.


Aruba is an associate member of the Association of Caribbean States (ACS). The primary purpose of the ACS is to be an organization for “consultation, cooperation and concerted action” for its member countries. Its framework provides a forum for political dialogue that allows Members the opportunity to identify areas of common interest and concern that may be addressed at the regional level, and the solutions for which can be found through cooperation. One of the areas identified by the ACS member states is trade and Economic External Relations. The ACS provides a framework for the dialogue and activity necessary to further advance economic integration and intra-regional trade and investment, thereby improving the economic competitiveness of the Greater Caribbean region.

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