Curaçao 2026: Tax Reform, VAT Plans and a New Era for Gaming Regulation
Curaçao's tax and regulatory framework is undergoing a significant transition in 2026, with developments affecting multinational groups, indirect taxation and the online gaming sector.
1. Curaçao's approach to Pillar Two
On 13 April 2026, the Minister of Finance confirmed Curaçao's updated policy position on the OECD's global minimum tax framework.
Curaçao will not introduce a Qualified Domestic Minimum Top-up Tax (QDMTT) and will continue not to pursue an Undertaxed Profits Rule (UTPR).
The Government has, however, maintained its intention to introduce an Income Inclusion Rule with intended retroactive application from 1 January 2025, subject to the parliamentary process and enactment.
For multinational groups with Curaçao entities, this provides greater clarity on Curaçao's intended approach to Pillar Two and the potential impact on local entities and parent companies.
2. VAT is moving closer
Curaçao is advancing plans to replace its current turnover/sales tax system with a modern VAT regime.
The VAT project has become a formal priority within Curaçao's 2026 reform agenda, alongside the modernization of the Tax Department. The proposed reform is intended to broaden the tax base, improve compliance and modernize the administration of indirect taxation.
The precise implementation timetable and final design of the VAT system remain under development.
For businesses operating in Curaçao, this means that pricing, invoicing, contracts, systems and tax compliance should be considered ahead of any eventual transition.
3. Corporate tax remains competitive, but the regime is becoming more targeted
Curaçao currently applies a corporate profit-tax rate of 15% on domestic profit up to ANG 500,000 and 22% on domestic profit above that threshold.
Certain qualifying activities may benefit from a 3% preferential rate, including specified activities in areas such as aircraft and shipbuilding, qualifying support services, warehousing and logistics, and services to investment funds and their managers, subject to the applicable conditions.
Curaçao also operates a territorial tax framework under which qualifying foreign-source activities may receive different treatment depending on the applicable rules and substance requirements.
For international groups, the interaction between these domestic rules, the territorial framework and Pillar Two has become increasingly important.
4. Gaming regulation is moving towards real local substance
The introduction of the LOK has fundamentally changed Curaçao's online gaming licensing framework, replacing the historical master-license/sub-license model with direct licensing through the Curaçao Gaming Authority.
Local substance is an important part of the new framework.
Under Article 5.12, licensed operators are subject to requirements concerning local presence and Key Persons. In January 2026, the Curaçao Gaming Authority announced that enforcement of the local-substance requirement would be postponed until 1 April 2027, giving operators additional time to prepare.
Certain smaller or newly established operators may qualify for an exemption from the local-substance requirements where they meet the conditions under Article 5.12, including the applicable XCG 20 million gross gaming revenue threshold, ownership conditions and ongoing reporting requirements.
The direction is clear: Curaçao's gaming framework is moving away from a purely offshore licensing model towards a structure requiring greater local presence, governance and accountability.
What does this mean for international businesses?
Curaçao remains an interesting jurisdiction for international businesses, but the 2026 environment requires more careful structuring.
Tax incentives, territorial taxation and international activities need to be considered alongside substance requirements, Pillar Two exposure, the upcoming VAT reform and sector-specific regulation.
Through Doing Business International (DBI), we help international clients:
- Assess Pillar Two exposure and Income Inclusion Rule implications for Curaçao entities.
- Prepare for the transition from sales tax to VAT and its impact on pricing and compliance.
- Structure gaming operations to meet the new local substance and reporting requirements.