Following the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework's release of the Side-by-Side Package in early 2026, the Government of Curaçao announced on 13 April 2026 that it will not be introducing a Qualified Domestic Minimum Top-up Tax (QDMTT). Curaçao will only implement an Income Inclusion Rule (IIR), which is intended to apply to fiscal years starting on or after 1 January 2025, subject to the parliamentary process and enactment. Curaçao also continues to not pursue an Undertaxed Profits Rule (UTPR).

This Tax Alert outlines Curaçao's updated policy position, provides background on the draft Minimum Tax Ordinance and highlights the main implications that may be relevant for multinational groups with a presence in Curaçao.

Pillar Two in Curaçao — background

In December 2025, the Minimum Tax Ordinance was formally submitted to Parliament as a separate law proposal to implement the OECD Pillar Two (Global Anti-Base Erosion, aka GloBE) framework in Curaçao, rather than as part of Curaçao's ordinary profit tax legislation.

In general terms, the OECD Pillar Two rules apply to constituent entities of multinational groups that meet the €750m consolidated revenue threshold in at least two of the four preceding fiscal years. Pillar Two aims to ensure that in-scope groups pay at least 15% in taxes in each jurisdiction in which they operate (based on Pillar Two effective tax rate mechanics). If the effective tax rate for Pillar Two purposes is below 15% in a jurisdiction, a top-up tax may arise under one of the Pillar Two charging mechanisms, such as the IIR, QDMTT or UTPR.

Following the OECD's release of the Side-by-Side Package (Administrative Guidance agreed by Inclusive Framework members) in January 2026, Curaçao reassessed its domestic approach. The Package also includes a Side-by-Side Safe Harbour that, where implemented and elected, generally switches off foreign IIR and UTPR exposure for eligible US-parented groups, while QDMTTs remain in point where jurisdictions have introduced them. (For more information, see EY Global Tax Alert, OECD releases Side-by-Side Package on Pillar Two Global Minimum Tax: Detailed review, dated 16 January 2026.)

Updated policy position in Curaçao

No QDMTT

In a public announcement dated 13 April 2026, the Minister of Finance indicated that Curaçao will not proceed with the introduction of a QDMTT. According to the announcement, this assessment followed analysis and consultations with stakeholders in the financial sector.

The Government indicated that introducing a QDMTT could reduce Curaçao's attractiveness as a jurisdiction, particularly for subsidiaries of US-parented multinational groups, in light of the international context following the Side-by-Side Package.

IIR

The Government has maintained its intention to implement the IIR with application intended from 1 January 2025 (subject to enactment). According to the announcement, this is intended to protect Curaçao-based parent entities from UTPR outcomes in other jurisdictions, reduce administrative burdens by allowing filings to be centralized in Curaçao, and reinforce Curaçao's commitment to international tax standards and compliance.

No UTPR

Consistent with the earlier draft, Curaçao does not intend to introduce the UTPR. According to the Government, the expected revenue from a UTPR would be limited and the measure's complexity would be disproportionate to the revenue collected.

What this may mean for in-scope groups with constituent entities in Curaçao

If enacted with application from 1 January 2025, in-scope multinationals with a fiscal year starting on or after 1 January 2025 should consider certain compliance obligations in Curaçao under a self-assessment framework. Depending on the circumstances, these obligations may include a local information return or, if the conditions for central filing are met, a notification to the tax authorities in Curaçao, as well as a minimum tax return and payment if IIR top-up tax is due.

Against this background, the draft Minimum Tax Ordinance would introduce two principal compliance obligations for in-scope groups:

1. Information return/notification

This local reporting obligation is intended to provide the information needed to support Pillar Two computations and disclosures. Depending on the filing structure, this may take the form of a local information return or, if the conditions for central filing are met, a notification to the Curaçao tax authorities identifying the filing entity and the jurisdiction in which the information return is filed. For the transition year, the deadline is 18 months after year-end, while for subsequent years the deadline is 15 months after year-end.

2. Minimum tax return and payment

This return is for the tax filing under the Curaçao minimum tax framework and is used to report any IIR top-up tax due and to settle the resulting payment in Curaçao in line with the self-assessment approach. The minimum tax return must be filed, and any tax due must be paid, within 17 months after year-end. For the transition year, that period is extended to 20 months after year-end.

Next steps

Affected entities that would like to discuss the next steps in the legislative process, the potential impact for their group (including whether any IIR top-up tax could be payable), or what the draft Minimum Tax Ordinance may mean in practice for the group's compliance obligations in Curaçao, should contact a knowledgeable tax advisor to help assess implications and any steps that may need to be taken.

EY Curaçao will continue to monitor both the Curaçao legislative process and international Pillar Two developments and will share further updates in Tax Alerts as more clarity becomes available.