People comparing Caribbean jurisdictions almost always treat the Dutch Caribbean as a single option sitting next to Panama, the Cayman Islands and Portugal on a spreadsheet. It is not one option. It is four, with different tax legislation, different constitutional positions, different economies and, in one case, a completely different currency and administration.
The distinctions matter, because the right answer for a retiring couple with pension income is rarely the right answer for an operating business, and neither is the right answer for someone whose priority is a European regulatory environment.
This is a structural comparison rather than a rate table. Rates change, and anyone choosing a jurisdiction on a rate they read in an article deserves the outcome they get.
The Constitutional Picture, Which Explains the Rest
Everything else follows from this, so it is worth two minutes.
Sint Maarten, Curaçao and Aruba are constituent countries within the Kingdom of the Netherlands. Each is autonomous in its internal affairs, and each has its own tax legislation, its own tax authority and its own parliament. They share a Kingdom, not a tax system.
Bonaire, together with Saba and Sint Eustatius, took a different path. The BES islands became special municipalities of the Netherlands, which puts them in a fundamentally different position: closer to the Dutch state, using the US dollar, and operating a fiscal system designed specifically for them rather than an inherited Antillean one.
The practical implication is that the three countries are genuinely separate jurisdictions to be assessed individually, while Bonaire is a different kind of proposition altogether and should not be compared on the same axis.
Sint Maarten
The shape of it: a tourism and services economy on a small, dense, extremely well-connected island shared with French Saint-Martin. Personal income tax on worldwide income for residents, profit tax at 34.5%, turnover tax at 5% without input credits, and, since 1 January 2026, a 10% dividend withholding tax on distributions.
What actually distinguishes it:
- The Penshonado regime, which for qualifying residents treats foreign source income at a flat 10%. For someone with substantial income arising outside the island, this is the single strongest feature of any of the four and the reason most relocations here happen. See the complete Penshonado guide.
- A remote worker exemption allowing foreign nationals up to 183 days in a rolling 12 months without local income tax, with matching thresholds for the foreign employer and for permanent establishment. See the 183-day exemption.
- Free port status. Customs here is primarily a law enforcement agency rather than a duty collector, which removes a cost that dominates importing across the rest of the region. See importing goods and vehicles.
- Connectivity. Princess Juliana is a genuine regional hub with direct North American and European service, which matters more to people who actually travel than any rate does.
- The French side. An open land border with a French, and therefore European, territory is a feature no other Caribbean jurisdiction offers. See French vs Dutch Sint Maarten.
The honest drawbacks: high cost of living, a thin tax treaty network, hurricane exposure that is a real and priced risk rather than a theoretical one, and an economy heavily concentrated in tourism.
Curacao
The shape of it: the largest of the three countries, with a broader and more diversified economy including refining, logistics, financial services and a substantial professional sector. Larger population, more institutional depth, and a longer history as a financial centre.
What distinguishes it: the professional infrastructure is deeper. If a structure needs local directors, specialist advisers, banking relationships and administrators, there are simply more of all of them. Curaçao also has more developed regimes aimed at international business, reflecting decades of positioning as a financial centre.
Where it costs you: more administration, generally more complexity, and an operating environment that reflects a larger state. Our dedicated comparison, Sint Maarten vs Curaçao, goes into the detail, and the short version is that Curaçao tends to suit substance-heavy structures while Sint Maarten tends to suit individuals and owner-managed businesses.
Aruba
The shape of it: the most tourism-dependent of the three and the most oriented toward the North American market, with the strongest consumer-facing economy and the highest visitor numbers relative to size.
What distinguishes it: a well-developed tourism sector, strong US connectivity, and a stable and comfortable living environment that consistently ranks well on quality of life. For a business whose customers are North American visitors, the market is genuinely there.
Where it costs you: Aruba's overall tax burden has historically been regarded as the heaviest of the three on both individuals and businesses, and it lacks a headline regime comparable to Penshonado for foreign source income. It is a good place to run a tourism business and a less obvious one to relocate substantial foreign income to.
Bonaire and the BES Islands
The shape of it: special municipalities of the Netherlands rather than autonomous countries, using the US dollar, with a fiscal system built for them rather than inherited. Small, quiet, diving-oriented, and closer to the Dutch state in both administration and regulation.
What distinguishes it: proximity to the Netherlands is the whole proposition. Dutch administration, Dutch regulatory standards and a closer institutional relationship, which for some Dutch nationals is precisely what they want and for others is exactly what they were leaving.
Where it costs you: scale. It is a small island with a small economy, limited professional services, limited connectivity and limited commercial opportunity. Excellent for a quiet life, constraining for a business.
The four jurisdictions revise their tax legislation independently and regularly. Sint Maarten introduced a dividend withholding tax with effect from 2026 and has a bill before Parliament to abolish two other taxes. A comparison built on a rate table found online is out of date on the day it is written. Choose on structure, on where you can actually build a life or a business, and on the regime that fits your specific income, then verify the current rates with an adviser in the jurisdiction before you commit.
Which One Suits Which Profile
| If you are | Look first at | Because |
|---|---|---|
| Retiring with substantial foreign source income | Sint Maarten | Penshonado at 10% on qualifying foreign income is the strongest feature in the group |
| Running a substance-heavy international structure | Curaçao | Deeper professional infrastructure, banking and administration |
| Operating a tourism business for the US market | Aruba or Sint Maarten | Aruba for visitor volume, Sint Maarten for connectivity and free port imports |
| A Dutch national wanting proximity to Dutch administration | Bonaire | Special municipality status, Dutch regulatory environment, US dollar |
| Importing and distributing goods regionally | Sint Maarten | No general import duty and hub connectivity |
| Working remotely for a foreign employer | Sint Maarten | An explicit statutory exemption up to 183 days rather than a marketing claim |
What the Comparison Usually Misses
Three things decide more relocations than any rate, and none of them appear on a comparison table.
Whether you can actually live there. These are small islands with real constraints on schooling, healthcare, professional opportunity for a spouse and social life. A tax saving does not survive a family that is unhappy after eighteen months, and the moves that fail almost always fail for this reason rather than a fiscal one.
Whether the structure will hold. Residence in any of them is a matter of fact, not of paperwork. Somebody who registers in a jurisdiction and continues to live substantially elsewhere has bought an argument rather than a position. See worldwide income and residence.
What your departure country does. For many people, the binding constraint is not the arrival jurisdiction at all. Exit charges, continuing obligations and, for US citizens, taxation on worldwide income regardless of residence, frequently matter more than the choice between these four. See US citizens in Sint Maarten.
The Short Version
The Dutch Caribbean is four jurisdictions, not one. Sint Maarten leads for individuals with foreign source income because of Penshonado, for remote workers because of an explicit statutory exemption, and for importers because of free port status. Curaçao leads on professional depth for substantial structures. Aruba leads on tourism market access. Bonaire leads for those who want the Netherlands at a distance rather than a different country.
Choose on structure and on liveability, then verify current rates before committing anything.
If you are weighing Sint Maarten against another jurisdiction, talk to us. We advise on the Sint Maarten position and will tell you plainly when another jurisdiction fits your facts better. Confirm current rates and regimes in each jurisdiction with local advisers before relying on any comparison, including this one.