Pillar 2 update: Parliament of Curaçao approves Pillar Two legislation

September 3, 2026

On September 1, 2026, the Parliament of Curaçao approved the draft National Ordinance on Minimum Tax 2024 (Landsverordening minimumbelasting 2024), which provides for the implementation of the OECD/G20 Pillar Two global minimum tax rules in Curaçao.

Under the legislation as approved by Parliament, Curaçao has opted for a targeted implementation of Pillar Two and will apply the Income Inclusion Rule (IIR) only. A Qualified Domestic Minimum Top-up Tax (QDMTT) and Undertaxed Profits Rule (UTPR) have not been introduced at this stage, although the legislative framework reserves the possibility of their introduction at a later stage.

The legislative proposal has been amended several times during the parliamentary process to reflect ongoing international developments. Most recently, technical amendments were introduced to the Curaçao Pillar Two framework, including changes arising from the OECD/G20 Inclusive Framework’s Side-by-Side package.

These amendments reflect Curaçao’s response to the evolving international Pillar Two framework and demonstrate that the local rules continue to develop alongside the broader international landscape. The version approved by Parliament on September 1, 2026, incorporates these latest amendments.

What this means for MNE groups

Following Parliament’s approval, the legislative process must still be completed through ratification and publication in the National Gazette of Curaçao.

In-scope groups should already prepare for implementation. Based on the information currently available, the first reporting deadline for calendar-year MNE groups within scope is expected to fall on June 30, 2027.

This leaves a relatively limited window for in-scope groups to assess their Curaçao position, identify relevant data requirements and determine how Curaçao entities fit within the group’s broader Pillar Two framework.

HBN Law & Tax has experience with both Pillar Two compliance and advisory matters, including the assessment of group structures, local Pillar Two implications and preparation for applicable reporting requirements.

We are available to assist in assessing the impact of the Curaçao rules, preparing for the upcoming compliance requirements and addressing related Pillar Two matters.

This update is intended for general information purposes only and does not constitute legal or tax advice.