Caribbean & Atlantic · 🇨🇼

Curaçao

A Dutch civil-law bridge jurisdiction within the Kingdom of the Netherlands, with treaty and Kingdom arrangements, real depth in licensing, shipping and international financial services, and an e-zone and gaming sector under reform that draws Dutch and Latin American structuring.

Legal systemDutch civil law · Kingdom of the Netherlands RegulatorCentral Bank of Curaçao & Sint Maarten (CBCS) Coordinates12.2°N · 69.0°W · Willemstad

Curaçao at a glance

Legal system
Dutch civil law; constituent country of the Kingdom of the Netherlands
Regulator
Central Bank of Curaçao and Sint Maarten (CBCS)
Company formation
The Curaçao Civil Code provides the NV (naamloze vennootschap) and BV (besloten vennootschap) corporate forms plus the SPF (Stichting Particulier Fonds / private foundation) used for wealth and asset-holding; formation occurs before a civil-law notary.
Trust regime
As a civil-law jurisdiction, Curaçao relies primarily on the SPF private foundation and the trust introduced into its Civil Code rather than common-law trusts; the SPF is the workhorse vehicle for succession and asset protection.
Tax posture
Curaçao levies profit tax with preferential regimes for qualifying export and innovation activity, and offers arrangements within the Kingdom of the Netherlands affecting cross-border flows. It participates in CRS and FATCA and applies international substance and transparency standards.
Region
Caribbean & Atlantic · Treaty · Licensing
How we act
Coordination by Hart David Carson LLP; local law advice by locally admitted counsel.

Curaçao is a Dutch civil-law jurisdiction inside the Kingdom of the Netherlands, which makes it less an offshore island than a bridge. Netherlands-facing and Latin American structures can be seated here under a familiar continental-European legal tradition, with treaty and intra-Kingdom arrangements that the pure zero-tax centers cannot offer.

That civil-law heritage shapes how work is done here. Companies and many instruments are executed before a civil-law notary, and the workhorse asset-holding vehicle, the Stichting Particulier Fonds or private foundation, descends from the same Dutch tradition as the foundations used across the Kingdom. For clients from continental Europe and Latin America, that familiarity is the point. The forms, the notarial process, and the supervisory posture of the Central Bank of Curaçao and Sint Maarten map onto institutions they already understand. Curaçao also has real sectoral depth, with a long history in licensing, shipping and international financial services and an e-zone and online-gaming sector that the island has been working to modernize.

Like its neighbors, Curaçao has moved with the international tide. It participates in CRS and FATCA reporting, applies international substance and transparency standards, and is reforming its gaming-licensing framework toward a modernized regulator and clearer standards. For a client weighing where to seat a holding company, a foundation or a licensed business, the appeal is the pairing of a respected civil-law system with a credible, treaty-aware tax posture that is demanding but coherent.

What we coordinate in Curaçao

Entity formation, foundations, banking, licensing and regulatory engagement, and tax posture, each assembled with a civil-law notary, licensed trust offices and Curaçao-admitted counsel.
01

Company & Entity Formation

We scope the company first, because in Curaçao the form is fixed in a notarial deed. The Curaçao Civil Code offers the naamloze vennootschap, or NV, and the besloten vennootschap, or BV, and we coordinate the choice between them for trading, holding and licensed-business structures with the civil-law notary and Curaçao-admitted counsel who execute and advise.

  • NV and BV companies established before a civil-law notary, who executes the deed of incorporation
  • BV favored for closely held and holding structures; NV for broader share-issuance and listed-style needs
  • Formation timelines reflect notarial drafting and know-your-customer processes typical of civil-law jurisdictions
02

Trusts & Foundations

The Stichting Particulier Fonds, or SPF, is the vehicle we most often coordinate here with Curaçao-admitted counsel: a private foundation with no shareholders that holds wealth for succession and asset-holding under a civil-law system that does not use the common-law trust. Where a trust form is needed, the statutory trust written into the Curaçao Civil Code is available.

  • SPF, an orphan foundation with no shareholders, used for wealth-holding, succession and asset protection
  • Statutory civil-law trust available where a trust form is required, distinct from the common-law trust
  • Established before a notary and administered through licensed trust offices, with advice by Curaçao-admitted counsel
03

Banking & Accounts

Curaçao has a local banking sector regulated by the Central Bank of Curaçao and Sint Maarten, supplemented by international institutions, with enhanced due diligence and source-of-funds standards consistent with international norms.

  • De-risking pressures have heightened documentation requirements for international clients; we prepare the file first
  • Substance, clear ownership charts and a credible business rationale materially improve onboarding outcomes
  • Introductions coordinated by the firm; the bank's decision and the account relationship remain its own
04

Regulatory & Licensing

The CBCS supervises banking, insurance, investment institutions and trust service providers and administers AML/CFT obligations, while international financial services and the e-zone operate under specific regimes.

  • Trust-service-provider, investment-institution and insurance supervision conducted by the CBCS
  • E-zone and international-financial-services regimes for qualifying export and service activity
  • Online-gaming licensing under reform toward a modernized regulator; matters before the CBCS handled with local counsel
05

Tax & Treaty Posture

Curaçao is not a zero-tax island, and that is part of its appeal. It levies profit tax, with preferential regimes for qualifying export and innovation activity, and its arrangements within the Kingdom of the Netherlands shape how cross-border flows are treated. We model those flows against the client's home position, and Curaçao tax advisers confirm each regime's conditions.

  • Profit tax with preferential treatment for qualifying export and innovation activity
  • Kingdom arrangements and Curaçao's Netherlands relationship relevant to inbound and outbound flows
  • CRS and FATCA reporting apply; home-country tax treatment is a separate question for the client's own tax counsel
On the ground

Government affairs &
facilitators, coordinated.

Engagement in Curaçao runs through the CBCS, the Chamber of Commerce, the tax authority, and civil-law notaries and licensed trust offices; commercial matters proceed before the Common Court of Justice. Hart David Carson coordinates a facilitation and partner network of Curaçao notaries, trust offices and licensing advisers, working alongside Curaçao-admitted counsel and notaries who provide formal advice and execution. We do not maintain a Curaçao office and act only as coordinator.

Civil-law notaries & licensed trust offices Chamber of Commerce & tax-authority filings Banking introductions & relationship onboarding CBCS & licensing engagement, with locally admitted counsel
Discuss a Curaçao matter →
How we coordinate a matter here

One partner,
the whole stack.

Hart David Carson scopes the Curaçao structure, an NV, a BV or an SPF, engages a civil-law notary and a licensed trust office, and project-manages licensing, banking and tax steps in concert with Curaçao-admitted counsel. One partner at the firm answers for the engagement while the local professionals render all formal legal advice and execution, so the structure is built once, correctly, with the home-jurisdiction and Curaçao pieces in the right order.

Scope the structure against the commercial objective and home-country position Engage a civil-law notary and a licensed trust office for execution and administration Project-manage formation, licensing and banking introductions end to end All local legal advice, opinions and notarial execution by Curaçao-admitted professionals
Start with a partner →

Prepared by Hart David Carson LLP · Reviewed by Jonathan D. Herpy, Sr. · Last updated October 2026 · Educational overview · Not legal advice · Local law advice comes from locally admitted counsel.

Frequently asked

Common questions on structuring in Curaçao.
Does Hart David Carson have an office in Curaçao?

No. Hart David Carson maintains no Curaçao office and does not practice Curaçao or Dutch civil law. We coordinate a facilitation and partner network of civil-law notaries, licensed trust offices, banks and licensing advisers, working alongside Curaçao-admitted counsel who provide all formal legal advice, opinions and execution. In a civil-law jurisdiction, incorporations and many instruments are executed before a notary.

Which Curaçao vehicles are typically used for cross-border structures?

Two companies and a foundation. The Curaçao Civil Code provides the naamloze vennootschap, or NV, and the besloten vennootschap, or BV, for trading, holding and licensed businesses. The Stichting Particulier Fonds (SPF), a private foundation, is the workhorse for wealth-holding and succession. Each is created by notarial deed, so expect the notary's drafting and know-your-customer process to set the formation timetable. Selection follows the commercial objective and is confirmed with Curaçao-admitted counsel and a civil-law notary.

What is a Curaçao SPF and how does it differ from a common-law trust?

An SPF is a legal person; a trust is a relationship. The Stichting Particulier Fonds is a private foundation with no shareholders, holding assets for private purposes such as succession and asset protection. Curaçao, being civil-law, uses the SPF and a statutory trust in its Civil Code, not the common-law trust. The foundation holds title in its own name, which simplifies banking. It is established before a notary, administered by a licensed trust office, with advice from Curaçao-admitted counsel.

Who regulates financial services in Curaçao?

The Central Bank of Curaçao and Sint Maarten (CBCS) supervises banking, insurance, investment institutions and trust service providers and administers anti-money-laundering and counter-financing-of-terrorism obligations. International financial services and the e-zone operate under specific regimes, and the online-gaming licensing framework has been undergoing reform toward a modernized regulator. Matters before the CBCS are conducted with Curaçao-admitted counsel.

How is Curaçao taxed, and what is its relationship to the Netherlands?

It taxes profits, from inside the Kingdom. Curaçao is a constituent country of the Kingdom of the Netherlands, with arrangements within the Kingdom that affect cross-border flows. It levies profit tax, with preferential regimes for qualifying export and innovation activity, and it participates in CRS and FATCA reporting and applies international substance and transparency standards. A preferential regime has to be earned with real activity on the island, so budget for substance. Home-country treatment is a separate question.

How does Hart David Carson coordinate a Curaçao matter?

Hart David Carson scopes the NV, BV or SPF structure, engages a civil-law notary and a licensed trust office, and coordinates licensing, banking and tax steps in concert with Curaçao-admitted counsel, who render all local legal advice and execution. You deal with one partner at the firm while the local professionals carry out the notarial and statutory work. Timelines depend on notarial and know-your-customer processes and are indicative only.

The structuring toolkit we bring

The firm-side capabilities most often brought into Curaçao work. One partner coordinates U.S. counsel and locally admitted advisers for each of them.

Treaty & international tax

Curaçao levies profit tax with preferential regimes for qualifying export and innovation activity, and offers arrangements within the Kingdom of the Netherlands affecting cross-border flows.

Treaty & international tax →

IP & licensing

In Curaçao, the CBCS supervises banking, insurance, investment institutions, and trust service providers, administering AML/CFT obligations; international financial services and the e-zone operate under specific regimes.

IP & licensing →

International tax

Curaçao combines a Dutch civil-law tradition with a treaty and tax-arrangement relationship to the Netherlands, making it a bridge jurisdiction for Dutch and Latin American structuring.

International tax →

International corporate structuring

The Curaçao Civil Code provides the NV (naamloze vennootschap) and BV (besloten vennootschap) corporate forms plus the SPF (Stichting Particulier Fonds / private foundation) used for wealth and asset-holding; formation occurs before a civil-law notary.

International corporate structuring →

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All Caribbean & Atlantic →  ·  ← Back to Global Reach

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Structuring in Curaçao?

One partner is accountable for the whole matter, and you have that partner's direct line. We coordinate the Curaçao pieces with locally admitted counsel and a civil-law notary; you keep one line back to the firm.