Bermuda consulting on corporate tax reform

Bermuda has issued a third public consultation paper on the proposed corporate income tax that would be apply to MNEs with annual revenue of EUR750m or more.

The Finance Ministry conducted two previous consultations in August and October. As a result of stakeholders’ feedback, the current proposal would introduce a corporate income tax that would be a covered tax under the OECD’s GloBE rules. This approach aims to minimize Top-Up taxes levied on Bermuda MNEs in other jurisdictions where they operate.

The corporate income tax legislation is intended to come into force in its entirety in January 2025, providing MNEs time to make transition adjustments.

The Government has proposed a statutory tax rate of 15 percent and is developing a robust package of Qualified Refundable Tax Credits (QRTCs) to maintain Bermuda’s attractiveness.

The latest consultation paper includes illustrative draft corporate income tax legislation to provide stakeholders with a comprehensive view of the proposed policy. Certain aspects of the law will be clarified with Guidance in 2023, and expanded in regulations intended to be published in 2024 and subsequent periods. The legislation is expected to be debated in the House of Assembly in December 2023.

Comments must be received by November 30.

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