Curaçao publishes final Pillar Two ordinance: IIR from 2025 and compliance deadlines

Curaçao published the Landsverordening minimumbelasting 2024 in P.B. 2026 no. 231 on 22 October 2026. The ordinance is dated 13 October. It puts the income inclusion rule (IIR) into enacted law, with the general application rule covering fiscal years beginning on or after 1 January 2025.

The final law implements an IIR

Article 1.1 imposes the income inclusion top-up tax under Chapter 4. Chapters 3 and 5, covering domestic top-up tax and the undertaxed profits rule respectively, are reserved. That is a material distinction from the earlier draft: the final ordinance does not introduce a Curaçao QDMTT or an operative UTPR charge.

Under Article 2.1, the regime applies to constituent entities of multinational groups meeting the €750 million consolidated revenue threshold in at least two of the four preceding reporting years, subject to the statutory exclusions. The threshold includes excluded-entity revenue and is adjusted proportionately for reporting years longer or shorter than twelve months.

Publication and fiscal-year application are different dates

Article 17.1(1) gives the ordinance effect from 1 January 2025 and first applies it to reporting years beginning on or after that date. Groups should therefore review their 2025 position now. The October 2026 publication date does not mean that only fiscal years beginning in late 2026 are affected.

The law also contains specific commencement and election provisions. In particular, Article 8.14 provides an elective safe harbour for a qualifying equivalent minimum-tax system for reporting years beginning on or after 1 January 2026. Eligibility and application dates need to be tested for the relevant provision.

Two compliance timetables

The GIR and foreign-filer notification are normally due within 15 months after reporting year-end. The separate IIR tax return and payment are normally due within 17 months. Article 14.3 provides transition-year periods of 18 months and 20 months, subject to its prior foreign-filing exception.

Central filing can relieve the local GIR obligation where the statutory conditions are met, but requires a local notification identifying the foreign filer and its location. It should be assessed separately from the IIR tax-return and payment position.

The member analysis below examines who is chargeable, the foreign-filing conditions, a calendar-year deadline example, the equivalent-system safe harbour and the correction and collection rules.

Source: Official Gazette, P.B. 2026 no. 231, Articles 1.1, 2.1–2.2, 4.1, 8.14, 11.1, 13.1, 14.3 and 17.1.