Pillar 2 update: Curaçao intends to shift to IIR-only model

April 23, 2026

As communicated in our earlier update (see this article), the Government of Curaçao has formally submitted the draft National Ordinance implementing the OECD Pillar Two Global Minimum Tax (hereinafter referred to as “Pillar Two”) to the Parliament.[1] In that context, we noted that consultation rounds were being held with relevant stakeholders, particularly in light of the OECD Side-by-Side Package, which provides additional technical guidance on the coordinated implementation of the GloBE rules.

Following the conclusion of these consultation rounds, the Minister of Finance, Mr. Charles Cooper, held a press briefing during which an update on Curaçao’s Pillar Two position was provided. During this briefing, it was announced that Curaçao’s approach has been amended. Specifically, Curaçao intends to adopt only the Income Inclusion Rule (IIR) as the charging mechanism. It was further clarified that Curaçao will not introduce a Qualified Domestic Minimum Top-Up Tax (QDMTT) or an Undertaxed Profits Rule (UTPR). This reflects a balance between international alignment and safeguarding Curaçao’s investment climate.

Against this background, it was noted that the implementation of a QDMTT is not considered opportune at this time. Based on the outcomes of the consultation process, such an approach would adversely impact investment attractiveness, particularly for subsidiaries of in-scope U.S.-based groups.

The IIR, as the sole charging mechanism, is intended to be enacted with retroactive effect as of January 1, 2025. As a result, the number of entities within the scope for Curaçao Pillar Two is expected to be significantly lower. In practice, the obligations will generally be limited to Ultimate Parent Entities and Partially Owned Parent Entities of in-scope groups established in Curaçao.

The Pillar Two framework is highly complex and requires proper alignment among tax, accounting, and legal functions. We continue to monitor developments in Curaçao, including any modifications arising out of parliamentary deliberations and administrative guidance.

This publication is provided for general informational purposes only and does not constitute legal or tax advice. The analysis is based on the draft legislation and publicly available materials as of the date of publication. The final legislative framework, including any transitional rules and administrative guidance, may differ from the current draft. No action should be taken or refrained from on the basis of this publication without obtaining specific advice tailored to the relevant facts and circumstances. Our tax and legal experts are available to assist you in evaluating the impact of the Pillar Two framework on your business activities in Curaçao.

[1] Landsverordening Minimumbelasting 2024.