GloBE Country Guide: Curacao

Summary

Status	Enacted — P.B. 2026 no. 231
Law	Landsverordening minimumbelasting 2024, P.B. 2026 no. 231, dated 13 October and published 22 October 2026. Historical: December 2024 draft.
Effective Date	Fiscal years beginning on or after 1 January 2025, subject to the specific commencement provisions in Article 17.1.
IIR	Yes (2025)
UTPR	No — Chapter 5 is reserved.
QDMTT	No domestic top-up tax under this ordinance — Chapter 3 is reserved.
Filing Deadlines	Standard
Safe Harbours	The final ordinance contains safe-harbour provisions in Chapter 8, including the Transitional CbCR Safe Harbour (Article 8.8) and the QDMTT Safe Harbour (Article 8.13). The latter concerns relief for qualifying tax in another jurisdiction; it does not create a Curaçao domestic top-up tax. Application is subject to the detailed conditions and commencement provisions.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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