Willemstad, 23 December 2025 

The Minister of Finance has submitted the draft National Ordinance on Minimum Tax 2024 to the  Parliament of Curaçao. 

The draft national ordinance is intended to implement the international agreements on the global  minimum tax for multinational enterprise groups, as established within the Inclusive Framework of the  Organisation for Economic Co-operation and Development (OECD). These agreements, known as  Pillar Two, have been further elaborated in the so-called side-by-side agreement between the OECD  and the G7, which provides for a coordinated and simultaneous implementation of the minimum tax  rules by participating states. 

These international agreements aim to ensure that multinational enterprise groups with a consolidated  annual turnover of at least EUR 750 million are subject to an effective minimum corporate income tax  rate of 15%, regardless of the jurisdiction in which they operate. The scope of the draft national  ordinance is therefore limited to entities that form part of a multinational enterprise group falling within  the scope of the OECD Pillar Two Model Rules. Accordingly, the proposed national ordinance  establishes a domestic legal framework under which a top-up tax may be levied if the effective tax rate  in Curaçao remains below the agreed minimum level. 

Through this draft, it is intended to align Curaçao’s tax legislation with internationally accepted  standards, as well as to protect the national tax base and mitigate the risk of base erosion and profit  shifting. Due consideration has been given to practicability, legal certainty, and consistency with  existing tax laws and regulations. 

In view of the complexity and international interdependence of the proposed legislation, the  Government considers a careful parliamentary review to be appropriate. It is intended that, following  approval by Parliament, the national ordinance will have retroactive effect as of 1 January 2025, in  accordance with what was already announced in the notice published in December 2024. This  retroactive effect is justified by the importance of an efficient and coherent implementation of the  regime and, in light of its timely announcement, does not undermine legal certainty or foreseeability  for the taxpayers concerned. In this context, it is envisaged that the parliamentary consideration of the  draft national ordinance will take place in January 2026. 

The Minister of Finance looks forward to the consideration by Parliament with confidence. 

Further explanation of the draft will be provided in the accompanying explanatory memorandum and  during the parliamentary proceedings.