To encourage investments in specific industries the Government has introduced a number of tax incentives on a selective basis.
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1 Aruba A. Definitions and sources of data The Bank of Aruba is responsible for the collection of foreign direct investment (FDI) data. The FDI definition as recommended in the Balance of Payments Manual: Fifth Edition of the International Monetary Fund is applicable to this economy. As an overseas territory of the Netherlands, Aruba is an associate of the European Union (EU). Because of this, the common import tariff of the EU single market is applied. However, Aruba does not form part of the EU fiscal area and consequently has its own tax policy. To encourage investments in specific industries the Government has introduced a number of tax incentives on a selective basis. A company operating in the non-traditional manufacturing industry, with an initial investment of at least AWG100,000 (app. $55,000) is eligible for incentives. For a maximum period of ten fiscal years, Aruba grants the following incentives: Reduction of corporate tax rate to zero per cent; Exemption from income tax on dividends paid out to shareholders, provided the dividends are paid within two years after the year the profit has been made; Exemption from import duties on building supplies for premises; Exemption from import duties on packing materials, machinery and equipment, raw materials, semi-manufactured products and components, to be used in the production process; and Exemption from real estate tax. Aruba has created a Free Zone (free trade zone) to boost exports and increase foreign exchange earnings. Only companies involved in "commercial" or "industrial" activities (which includes the service, repair and maintenance of goods with a foreign destination) can be licensed to operate within the Free Zone. Free Zone companies receive substantial fiscal incentives including exemption from import duties and low rates of taxation. They also benefit from a simplified administrative regime.
2 B. Statistics on FDI and the operations of TNCs
3 Table 1. Summary of FDI Variable Inward Outward 1. FDI flows, (annual average) FDI flows as a percentage of GFCF, (annual average) FDI stock, FDI stock as a percentage of GDP, Sources : Based on tables 3 and 4 and UNCTAD, FDI/TNC database. Note: Data for 2003 are estimates.
4 Table 3. FDI flows, by type of investment, Year Equity Inward investment Intracompany Reinvested earnings loans Total Equity Outward investment Intracompany Reinvested earnings loans Total Sources: UNCTAD, FDI/TNC database. FDI inflows are based on information from the Bank of Aruba for and UNCTAD estimates. FDI outflows are based on information from the Bank of Aruba. Note: Data for 2003 are estimates.
5 Table 4. FDI stock, by type of investment, Year Equity Inward investment Intracompany Reinvested earnings loans Total Equity Outward investment Intracompany Reinvested earnings loans Total Sources: UNCTAD, FDI/TNC database. Notes: Inward stock is an accumulation of inflows since Outward stock is an accumulation of outflows since 1993.
6 Table 6. FDI flows in the host economy, by geographical origin, Economy Belgium / Luxembourg Colombia Japan Netherlands United States Notes: Data are based on information reported by the economies listed above. Data for Japan are on an approval basis. Table 9. FDI flows abroad, by geographical destination, Economy Belgium / Luxembourg Brazil Colombia France Netherlands United States Venezuela Note: Data are based on information reported by the economies listed above. Table 12. FDI stock in the host economy, by geographical origin, Economy Colombia Netherlands United States Note: Data are based on information reported by the economies listed above. Table 15. FDI stock abroad, by geographical destination, Economy Brazil Colombia El Salvador Netherlands United States Venezuela Note: Data are based on information reported by the economies listed above.
7 Tables 21,28,33,38,43,48,53. Number, assets, employment, wages and salaries, sales, value added and profits of foreign affiliates of Aruban TNCs in the United States, (Number, thousands of employees and millions of dollars) Table no. Variable Number Assets Employees Wages and salaries Sales Value added Profits before taxes Note: Data are based on information reported by the United States. Tables 23,30,35,40,50. Number, assets, employment, wages and salaries and value added of affiliates of United States TNCs in Aruba, (Number, thousands of employees and millions of dollars) Table no. Variable Number Assets Employees Wages and salaries Value added Notes: Data are based on information reported by the United States. Data for assets and value added refer to majority-owned affiliates only.
8 Table 88. Largest affiliates of foreign TNCs in the host economy, 2002 (Millions of dollars and number) Company Home economy Industry Sales Employees A. Industrial Coastal Aruba Refining Co. N.V. United States Petroleum Dijtham Aruba N.V. Netherlands Antilles Machinery and equipment.. 11 Guasare Coal International N.V. Venezuela Mining and quarrying.... B.O.C. Gases Aruba N.V. United Kingdom Chemicals.... IBM World Trade Corporation United States Electrical and electronic equipment.... B. Tertiary Consales Aruba, N.V. Netherlands Antilles Trade Arimco Aruba N.V. Netherlands Antilles Construction.. 38 Croon Elektrotechniek Aruba N.V. Netherlands Construction.. 36 Unisalou Corporation N. V. Netherlands Antilles Trade.. 35 Aruba Agencies N. V. Netherlands Antilles Trade.. 25 Aruba Agencies N. V. Anguilla Trade.. 25 Coastal Petroleum N.V. United States Trade.. 13 Angelo Aruba N.V. Netherlands Antilles Trade.. 8 Hagemeyer (Aruba) N.V. Netherlands Trade.. 6 Federal Express ( Aruba) N.V. United States Transport and storage.... Pdvsa Marketing International (Aruba) Venezuela Trade.... J.F. Caribe A.E.C. Japan Other business services.... Aruba Refinery Rehabilitation Company United States Other business services.... C. Finance and Insurance Assets Employees Caribbean Mercantile Bank N.V. Netherlands Antilles Finance a Inarco International Bank N.V. United States Finance.... Mtbc Finance (Aruba) A.E.C. Japan Other business services.... Rbtt Bank Aruba N.V. Trinidad & Tobago Finance.... Banco La Guaira (Aruba) N.V. Venezuela Finance.... Sources: The Banker's Almanac, 2003 (London, Reed Information Services, 2003); Thomson Analytics ( Who Owns Whom, 2003 (London, Dun and Bradstreet, 2003); and information from ECLAC. a December 2001.
9 C. Legal framework for FDI I. National policy framework Legislation establishing the Aruba Exempt Corporation (AEC) or Aruba Vrijgestelde Vennootschap 1988 Source: 1 March 2004 New Tax Legislation 1999, (effective) 1st January 2003 Source: Ibid Central Bank Ordinance 1985 Source: Ibid The Commercial Code of Aruba National Ordinance on Penalization of Money Laundering 1996 Source: Ibid National Ordinance on Profit Tax State Ordinance on Foreign Exchange Transactions State Ordinance on Supervision of the Credit System 1998 Source: Ibid II. International framework 1. Multilateral and regional instruments General Agreement on Trade in Services 1994, (effective 1 January, 1995), Fourth Protocol to the General Agreement on Trade in Services 15 February 1997, Fifth Protocol to the General Agreement on Trade in Services 12 December 1997 The ILO Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy, adopted 16 November Bilateral treaties Bilateral treaties for the avoidance of double taxation with United States 1948 Income and Capital, Netherlands 1964 Income and Capital, United States 1986 Income and Capital, Panama 1997 Air and Sea Transport Source: UNCTAD database on BITs and DTTs
10 D. Sources of information Official 1. Central Bank of Aruba: Secondary 1. Anonymous, Valero signs deal for Aruba refinery; Refiner to pay $365 million for plant that was made for us, San Antonio Express-News, 5 February 2004, p Boisclair, Marc, The Caribbean: better than ever, Incentive, April 1998, vol. 172, No. 4, pp Jayawardena, Chandana and Diaram Ramajeesingh, Performance of tourism analysis: a Caribbean perspective, International Journal of Contemporary Hospitality Management, 2003, vol. 15, No. 3, p Luxner, Larry, Projects support healthy Caribbean tourism, Hotel and Motel Management, 16 June 1997, Vol. 212, No. 11 p McCartney, Scott, El Paso Corporation sees over $1.5 billion in write-downs, Wall Street Journal (Eastern edition), 14 July 2003, p. C11.
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