Aruba 2026: New Tax Incentives, Expanded Free Zone, and Improved Expatriate Rules

As of 1 January 2026, Aruba rolled out a coherent package of fiscal incentives designed to attract investment and talent. A new start-up regime grants companies incorporated in Aruba from 2026 in designated "promising sectors" (knowledge economy, agriculture, logistics, circular economy, creative industries, and niche tourism, while the Government also refers to cultural and medical tourism) an annual profit tax exemption on profits up to Afl. 50,000, an enhanced investment allowance rising from 10% to 20% for qualifying investments of at least Afl. 5,000, and a 50% deduction on new business loans up to Afl. 30,000 per year, all for the first five financial years post-incorporation, subject to economic substance, local core revenue-generating activities, employment, and other applicable requirements, and excluding companies under the Free Zone regime. The scheme is currently implemented through "beneficial policy", pending formal legislation.

Separately, a favourable fiscal policy for Oranjestad and San Nicolas offers qualifying local and foreign investors a 10-year exemption from profit tax and dividend withholding tax, plus temporary exemptions from transfer tax, BBO, and the AZV destination levy in connection with qualifying redevelopment and sale transactions.

Aruba's Free Zone regime was also significantly expanded: AB 2025 no. 45, effective 1 January 2026, broadened the types of service activities permitted in the zone, while maintaining a preferential profit tax rate for qualifying income (2% profit tax on qualifying Free Zone profits), subject to the applicable Free Zone admission, substance, and activity requirements, with related party transactions still subject to arm's length rules. The expanded framework covers areas including:

• ICT, data, AI, and cybersecurity;
• media, streaming, and audiovisual activities;
• aviation and maritime engineering;
• scientific research;
• certain professional services and education;
• various technology and specialized services.

Aruba offers a relatively straightforward corporate establishment framework, including NV and VBA structures, with foreign ownership generally permitted subject to applicable licensing and regulatory requirements. The standard corporate income tax rate is 22%, alongside various preferential regimes and incentives.

On the compliance side, the 2026 fringe-benefit reforms expanded access to the expatriate regime. In particular, employees with at least an HBO degree and five years of relevant experience can potentially qualify, in addition to the existing high-salary/special-skills route. The maximum tax-exempt housing allowance was also increased to Afl. 3,500 per month, while the maximum tax-exempt expatriate allowance increased to Afl. 20,000 per year.

Through Doing Business International (DBI) and our partners in Aruba, we help international clients:

• Assess eligibility for the new start-up regime and Oranjestad/San Nicolas redevelopment incentives.
• Structure operations under the expanded Free Zone regime with proper economic substance.
• Navigate incorporation, fringe benefit, and expatriate rules under Aruba's 2026 tax framework.