WILLEMSTAD – Curaçao has taken another significant step in expanding its international tax treaty network by signing a double taxation agreement with Cyprus. The agreement was officially signed today during a ceremony at the Embassy of Cyprus in Washington, D.C.
The treaty was signed by Curaçao’s Minister of Finance, Javier Silvania, and Cypriot Ambassador Evangelo Savva. The Kingdom’s delegation included Germaine Rekwest, Curaçao’s lead tax treaty negotiator, and Denis Leeflang from the Dutch Embassy in Washington.
The tax treaty establishes rules determining which of the contracting states has the authority, under its national legislation, to levy taxes on the income of residents from one or both of the contracting parties. Additionally, the agreement includes provisions aimed at preventing tax evasion and avoidance, such as mutual consultation mechanisms, exchange of information, and assistance in tax debt collection.
This new treaty aligns with Curaçao’s broader goal of expanding its tax treaty network to promote sustainable economic development.
The text of the agreement will soon be published in the Kingdom's Treaty Gazette (Tractatenblad). However, the treaty will only enter into force after it has gone through the national ratification processes in both Curaçao (as part of the Kingdom of the Netherlands) and Cyprus. Curaçao is working closely with the Department of Foreign Relations (DBB) and the Ministry of Foreign Affairs in The Hague (Treaty Division) to complete the ratification process.
Curaçao now has tax treaties in place with four countries: Suriname, San Marino, Malta, and Cyprus. The treaty with Malta came into effect on January 1, 2025.
Background on the Cyprus Tax Treaty
In early 2023, Curaçao initiated discussions with Cyprus to explore the possibility of negotiating a bilateral tax treaty aimed at strengthening economic relations and administrative cooperation between the two jurisdictions. Following a meeting between Minister Javier Silvania and the Cypriot delegation during the April 2023 IMF Meetings in Washington, both sides agreed to start formal negotiations.
Later that year, both countries exchanged model treaty texts. At Cyprus’s request, negotiations were scheduled for 2024. Technical discussions were held in Nicosia on September 24–26, 2024, culminating in the initialing of the draft treaty text by both delegations on September 26.
The structure, content, and wording of the treaty closely follow the OECD Model Tax Convention. Curaçao’s negotiation approach was guided by its 2023 Fiscal Treaty Policy.
