Executive Summary
This week’s Curaçao tax intelligence focuses on the enactment of Pillar Two minimum tax legislation, alongside operational updates on Dutch social security premium caps and emerging short-term rental registration requirements across the Dutch Caribbean.
Important Updates
Curaçao Enacts National Ordinance Minimum Tax 2024 Under Pillar Two
The Government of Curaçao has officially published the National Ordinance Minimum Tax 2024 (Landsverordening Minimumbelasting 2024) in the Official Gazette (Publicatieblad 2026, No. 87), implementing the OECD/G20 Pillar Two Global Anti-Base Erosion (GloBE) Rules. Enacted by Parliament on October 15, 2026, the ordinance enters into force for fiscal years beginning on or after January 1, 2027, and aligns with the EU Minimum Tax Directive (2022/2523) as extended to the Caribbean parts of the Kingdom via the Kingdom Act (Rijkswet). The Ministry of Finance of Curaçao issued the measure in coordination with the Dutch State Secretary for Finance.
The ordinance introduces a 15% minimum effective tax rate for constituent entities of multinational enterprise (MNE) groups with consolidated annual revenue exceeding €750 million in at least two of the four preceding fiscal years. Curaçao will apply a domestic top-up tax through a Qualified Domestic Minimum Top-Up Tax (QDMTT) rather than a standalone Income Inclusion Rule, while the Undertaxed Profits Rule remains reserved for future activation and the Subject to Tax Rule is incorporated for treaty-covered payments. The law adopts GloBE mechanical rules for computing the Effective Tax Rate and Top-Up Tax, including a substance-based income exclusion of 5% of eligible tangible assets and payroll, and codifies transitional safe harbors per OECD Agreed Guidance 2024.
The regime directly affects approximately 40 MNE groups headquartered in or operating through Curaçao, spanning financial services, e-gaming, tourism, and international holding structures. Entities benefiting from the Curaçao Innovation Box (9% effective rate) or the e-zone regime (2% profit tax) will face top-up obligations unless the substance-based exclusion eliminates GloBE income. Affected groups must register with the Curaçao Tax Authority via the new Pillar Two portal by March 31, 2027, and file the first GloBE Information Return 18 months after fiscal year-end—July 31, 2028 for calendar-year groups—with top-up tax due simultaneously. Penalties reach AWG 50,000 per month for late filing (capped at AWG 500,000) and up to 100% of underpaid top-up tax for inaccurate returns.
Sources: HBN Law & Tax
Secondary Regulatory & Regional Updates
- Applicable Limitation Provision for ZV and OV Premiums: The annual income cap for Ziekteverzekeringswet (ZV) and Ongevallenverzekeringswet (OV) premiums is fixed at €71,628 for the 2026 premium year, applied uniformly to employer and employee contributions while excluding certain tax-free allowances such as travel expenses under the Willem Drees scheme. Employers must update payroll systems by the November 2026 payroll cycle and reconcile year-to-date premiums by December 31, 2026, with SVB automated validations beginning January 2027. HBN Law & Tax
- Short Term Rental Registration Requirements: A mandatory registration regime is being introduced for short-term rental properties across the Dutch Caribbean, requiring digital registration, display of unique registration numbers on listings, and linkage to tax authorities for income tax, turnover tax, and tourist tax cross-referencing. Operators and platforms should verify effective dates and transition periods to avoid administrative fines, back-tax assessments, and delisting of unregistered units. HBN Law & Tax
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.