The Minister of Finance hereby announces that the Government of Cura\u00e7ao 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.<\/p>\n
Policy reassessment in light of international developments<\/strong><\/p>\n 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.<\/p>\n Where Cura\u00e7ao had initially intended to implement both a Qualified Domestic Minimum Top-up Tax (QDMTT)<\/strong> and an Income Inclusion Rule (IIR)<\/strong>, it has now been decided\u2014following extensive analysis and consultations with key stakeholders in the financial sector\u2014to adjust this course.<\/p>\n No implementation of QDMTT<\/strong><\/em> The Government considers it not opportune to implement the QDMTT at this time<\/strong>. Recent consultations indicate that introducing this measure would reduce Cura\u00e7ao’s attractiveness as a jurisdiction, particularly for subsidiaries of U.S.-based multinational groups.<\/p>\n 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 Cura\u00e7ao at a competitive disadvantage.<\/p>\n Implementation of IIR maintained<\/strong><\/em> The Government maintains its intention to implement the Income Inclusion Rule (IIR) with retroactive force per 1 January, 2025<\/strong>. This measure:<\/p>\n No implementation of UTPR<\/strong> 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.<\/p>\n Balancing competitiveness and international commitments<\/strong> With this revised approach, Cura\u00e7ao adopts a balanced strategy aimed at:<\/p>\n Outlook<\/strong> 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 Cura\u00e7ao’s investment climate through both fiscal and non-fiscal measures.<\/p>\n With this carefully considered approach, we ensure that Cura\u00e7ao remains competitive while fulfilling its international responsibilities. We deliberately choose measures that add real value to our economy and strengthen our position globally.<\/p>\n\n
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