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5th of September 2010
   
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Fiscal Incentives

To encourage investments in specific industries the Government offers tax incentives on a selective basis. These fiscal incentives are for the purpose of the broadening of the economic base.

Manufacturing industries are allowed to import packing materials, raw materials, semi-manufactured products and components to be used in the production process free of customs duty.

The shareholders of an Aruban N.V., hereinafter called the Imputation Payment Company or IPC, which performs qualifying activities, are entitled to receive imputation payment from the tax authorities upon the payment of dividends.


Which activities qualify?

  • Quality hotel business operations (one of the conditions to be met is that the average room charge should be at least Af 354 per day);
  • International air and sea transportation (with each seperate vessel having a minimum net tonnage of 2.500 tons);
  • Developing, acquiring, keeping, maintaining and licensing of patent, copyrights, video rights, music rights and trademark rights;
  • The development, acquisition and exploitation of information and communication technology;
  • Captive insurance activities;
  • The financing of other enterprises and companies whether or not inter company, but excluding banking activities;
  • Qualifying holding and 'passive' investment activities;
  • A company aimed towards generating renewable energy;

How does the imputation system work?
An IPC is subject to the ordinary profit tax rate of 28%. However after the company distributes dividends, the shareholder becomes entitled to an imputation payment of 26/72 of the dividend. Assuming the IPC's profit is 100 and the IPC paid 28 as profit tax, 72 is available for distribution. If the IPC pays a dividend of 72, the shareholder becomes entitled to an imputation payment by the Government of Aruba of 72*26/72=26. This means that the effective profit tax rate of an IPC is only 2 %.

The IPC has to withhold dividend tax of 10% on both the dividend and the imputation payment: 10% of (72+26)=9.8. If the ultimate parent company or the IPC itself is quoted on an acknowledged stock exchange, the dividend withholding tax will be reduced to 5%. The rate may also be reduced to 5% on the basis of the Tax Arrangement for the Kingdom.
Contact: www.siad.aw