Pillar 2 update: Curaçao publishes minimum tax legislation

October 29, 2026

On October 22, 2026, Curaçao published the National Ordinance on Minimum Tax 2024 (Landsverordening minimumbelasting 2024) in the National Gazette (P.B. 2026, no. 231). This completes the legislative process following Parliament’s approval on September 1, 2026.

The legislation applies to financial years beginning on or after January 1, 2025. Curaçao has adopted the Income Inclusion Rule (IIR), without introducing a Qualified Domestic Minimum Top-up Tax (QDMTT) or an Undertaxed Profits Rule (UTPR). The regime generally covers multinational groups with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding financial years.

The legislation also incorporates transitional safe harbour provisions, which may simplify GloBE calculations and reduce or eliminate top-up tax liabilities where the applicable conditions are met. However, the application of a safe harbour does not automatically eliminate the relevant reporting and filing obligations.

For calendar-year groups applying the transitional filing extensions to financial year 2025, the relevant deadlines are:

• June 30, 2027: GloBE Information Return (GIR) or local notification, as applicable.
• August 31, 2027: Curaçao minimum tax return and payment, where required.

Earlier deadlines may apply where these transitional extensions are unavailable. Groups should therefore confirm their applicable deadlines, assess the availability of relevant safe harbours, and determine whether any Curaçao reporting or payment obligations arise, including where no local top-up tax is payable.

HBN Law & Tax combines experience in Pillar Two advisory and compliance with detailed knowledge of Curaçao’s tax and legal framework. Our tax advisers and lawyers can assist your group with scoping and safe harbour assessments, effective tax rate and top-up tax calculations, GIR reporting, local notifications and the preparation of Curaçao minimum tax returns. We also help coordinate these obligations with your group’s international Pillar Two compliance framework, supporting a consistent and practical approach to local and group-wide requirements.

Please contact your usual HBN adviser or our tax team to discuss how the new legislation affects your group and how we can support your preparations.