The Government of Curaçao has officially published the National Ordinance Minimum Tax 2024 (Landsverordening Minimumbelasting 2024) on 29 October 2026, implementing the OECD/G20 Inclusive Framework’s Pillar Two Global Anti-Base Erosion (GloBE) Rules. The legislation introduces a 15% domestic minimum top-up tax (DMTT) for multinational enterprise (MNE) groups with consolidated annual revenues exceeding €750 million, effective for fiscal years beginning on or after 1 January 2025. Curaçao adopts the Income Inclusion Rule (IIR) as its primary mechanism, with a qualified domestic minimum top-up tax (QDMTT) to protect its tax base. The ordinance aligns with the EU Directive 2022/2523 and includes safe harbor provisions, filing obligations via the Curaçao Tax Authority (Belastingdienst), and penalties for non-compliance. This move follows the Parliament’s approval in September 2026 and positions Curaçao as a compliant jurisdiction under the global minimum tax framework.
Key Takeaways
- Effective Date and Scope: The DMTT applies to fiscal years starting 1 January 2025, covering MNE groups meeting the €750 million revenue threshold, with the IIR applied at the ultimate parent entity level.
- Qualified Domestic Minimum Top-Up Tax: Curaçao’s QDMTT ensures that any top-up tax on low-taxed income arising in Curaçao is collected domestically first, reducing the risk of foreign IIR collections.
- Filing and Compliance: Affected groups must file a GloBE Information Return within 15 months after the fiscal year-end (extended to 18 months for the first year), with the first return due for FY2025 by 30 June 2027.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement