The Minister of Finance hereby announces that the Government of Curaçao has determined its position regarding the implementation of the Pillar 2 framework, following the recent publication of the Side-by-Side Package by the OECD.

Policy reassessment in light of international developments

Recent international tax developments, in particular the OECD’s revised position on the United States and its implementation in the OECD Side-by-Side Package (January 2026), have led to a fundamental reassessment of the previously intended policy.

Where Curaçao had initially intended to implement both a Qualified Domestic Minimum Top-up Tax (QDMTT) and an Income Inclusion Rule (IIR), it has now been decided—following extensive analysis and consultations with key stakeholders in the financial sector—to adjust this course.

No implementation of QDMTT The Government considers it not opportune to implement the QDMTT at this time. Recent consultations indicate that introducing this measure would reduce Curaçao’s attractiveness as a jurisdiction, particularly for subsidiaries of U.S.-based multinational groups.

The Side-by-Side Package effectively limits the application of certain foreign top-up taxes in these cases, meaning that a domestic QDMTT could place Curaçao at a competitive disadvantage.

Implementation of IIR maintained The Government maintains its intention to implement the Income Inclusion Rule (IIR) with retroactive force per 1 January, 2025. This measure:

• protects Curaçao-based parent entities from complex foreign taxation (such as the UTPR);
• reduces administrative burdens by enabling centralized filing in Curaçao;
• reinforces Curaçao’s commitment to international tax standards and compliance.

No implementation of UTPR Consistent with earlier considerations, the Undertaxed Profits Rule (UTPR) will not be implemented. Given its limited expected revenue and complexity, the Government does not consider its introduction to be efficient or proportionate.

Balancing competitiveness and international commitments With this revised approach, Curaçao adopts a balanced strategy aimed at:

• preserving and strengthening its investment climate;
• aligning with international standards;
• limiting administrative and implementation burdens for both government and businesses.

Outlook The Government will continue to closely monitor international developments and remains prepared to further adjust its policy where necessary. At the same time, efforts are underway to enhance Curaçao’s investment climate through both fiscal and non-fiscal measures.

With this carefully considered approach, we ensure that Curaçao remains competitive while fulfilling its international responsibilities. We deliberately choose measures that add real value to our economy and strengthen our position globally.

For any further questions, please contact the Directorate of Fiscal Affairs at 4328873 or via email at runela.sille@gobiernu.cw.

The Minister of Finance Mr. Charles Cooper