Global Daily Tax News, Curacao Implementing Pillar Two Framework From 2025, (Nov 15, 2024)

Caribbean territory Curacao will implement a minimum top-up tax regime under the OECD's Pillar Two international tax framework from 2025.

The territory's Council of Ministers has approved a regulation for the implementation of a 15-percent domestic top-up tax on in-scope multinational enterprises as well as implementation of the income inclusion rule (IIR).

Under the IIR, the undertaxed profits of foreign subsidiaries of corporate groups established in Curacao will be liable to a top-up tax in Curacao to ensure the application of an effective 15 percent tax rate on profits.

The announcement follows a series of consultations with the private sector during the early part of this year.