Curaçao’s decision to implement an Income Inclusion Rule only demonstrates a measured commitment to the OECD’s global minimum-tax framework, while ensuring that the regime is tailored to the jurisdiction’s own economic interests. This is a pragmatic and defensible option for a country with important economic ties with the United States, the only Side-by-Side nation so far.
Dr Leopoldo Parada
04 September 2026
King's academic's advice influences major tax legislation in Curaçao
Dr Leopoldo Parada has contributed to new legislation on the Global Minimum Tax (GMT) passed in Curaçao.
The National Ordinance on Minimum Tax 2024, recently adopted by the Parliament of Curaçao, has been influenced by advice provided by Dr Leopoldo Parada on the implementation of the Global Minimum Tax through an Income Inclusion Rule (IIR). Under the IIR, Curaçao may impose a top-up tax on Curaçao-resident parent entities where constituent entities of their multinational groups are taxed below the 15% minimum rate in another jurisdiction. The Ordinance therefore adopts a parent-jurisdiction approach, opting out from the Qualified Domestic Minimum Top-up Tax (QDMTT) to collect top-up tax on low-taxed profits arising in Curaçao.
In March 2026, Dr Parada published a paper, The SbS Package and the Irony of Global Tax Cooperation, which influenced significant amendments to the draft legislation that has now been approved.
As a member of the task force established to facilitate the legislative process, Dr Parada participated in extensive consultation rounds with key stakeholders as the draft legislation underwent successive stages of review and refinement.
Curaçao has now decided to adopt the Income Inclusion Rule, which safeguards local parent companies while demonstrating the country's commitment to the Organisation for Economic Co-operation and Development (OECD) framework and, by extension, the global financial community.
This legislation marks a significant development in Curaçao's tax framework and is set to be presented to the Government for ratification. Once ratified, it will be enacted with retrospective effect from 1 January 2025.
Dr Leopoldo Parada is a Reader in Tax Law and Director of the LLM in International Tax Law at The Dickson Poon School of Law. He also serves as a tax policy adviser to governments and international organisations around the world.
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Reader in Tax Law