Amended tax laws of the BES-islands (BES-islands)

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On October 27, 2026, the BES Islands Tax Omnibus Act (Fiscale verzamelwet BES eilanden 2027) was officially published in the Dutch Government Gazette. The act has therefore been enacted and will generally enter into force on January 1, 2027. One technical amendment to the Douane- en Accijnswet BES applies retroactively from 1 January 2011.

The Act introduces a series of technical, procedural and substantive amendments affecting the BES Islands as part of the modernization of the BES tax system. It is primarily intended to eliminate legislative inconsistencies, improve the administration of the tax system and address operational bottlenecks encountered by the Caribbean Netherlands Tax Administration.

Real Estate Tax

The Act raises the reduced real estate tax rate for hotels owned by non-natural persons from 11% to 12%. This adjustment continues the phased increase toward the standard commercial real estate tax rate of 17.5%

General Expenditure Tax (ABB)

Upon joint written request, a BES parent company and one or more wholly owned BES subsidiaries may be treated as a single entrepreneur or producer for ABB purposes. Consequently, supplies and services within the fiscal unity generally do not give rise to ABB. Subsidiaries forming part of the fiscal unity may be jointly and severally liable for ABB due by the parent company. The Act also introduces an ABB exemption for certain locally supplied goods used in the agricultural sector, aligning their treatment more closely with qualifying agricultural goods that can already be imported free of ABB.

Transfer Tax

To further encourage agricultural activity, the Act introduces a transfer tax exemption for the acquisition of agricultural land intended for continued agricultural use. The exemption also covers the acquisition of leasehold rights over such agricultural land. The agricultural use must generally be continued for at least ten years. Otherwise, the transfer tax initially relieved may become payable.

Formal tax law and collection measures

Starting 1 January 2027, the Caribbean Netherlands Tax Administration will have additional statutory powers to support tax collection. These include the authority to immobilize vehicles for the execution of tax enforcement orders and to serve certain enforcement orders by post.

The time limit for imposing administrative penalties for failure to submit the required third-party information reports will also increase from 1 year to 4 years.

Personal Income Tax

The Act introduces two amendments to the personal income tax rules. First, the special rule allowing certain deductions to be allocated between spouses in the year of separation or divorce will be abolished. Second, the calculation of the tax-free allowance will be clarified. The tax-free allowance will be linked to the highest statutory of the three applicable statutory minimum wage amounts for Bonaire, Sint Eustatius and Saba.

Wage Tax

The Act introduces changes to the tax treatment of shared company vehicles and the customary wage rules for director-majority shareholders (DGAs). For company vehicles that are continuously and alternately used by two or more employees, employers may apply a final levy where it is impractical to attribute the taxable benefit to individual employees. The final levy is set at 7.5% of the vehicle’s new value per year, provided the statutory conditions are met.
The customary wage rules for DGAs are also amended. The statutory reference amount is set at USD 43,912. Going forward, this amount will no longer be linked to the BES tax-free allowance but will instead be adjusted annually using the general table correction factor.

Entry into Force

The BES Islands Tax Omnibus Act 2027 was signed on October 7, 2026 and officially published in the Dutch Government Gazette (Staatsblad 2026, 334) on October 27, 2026. Most of the amendments will enter into force on January 1, 2027. enter into force on January 1, 2027. One technical amendment to the customs and excise legislation applies retroactively from January 1, 2011.

Keep in touch

Our team of tax professionals can assist businesses, employers, investors and property owners in assessing how the BES Islands Tax Omnibus Act 2027 may affect their activities in Bonaire, Sint Eustatius and Saba and in preparing for the changes taking effect from 1 January 2027.

Should you have any questions regarding this announcement, please do not hesitate to contact us. Our team would be more than happy to assist you with your questions.