Bermuda

With the assent of the governor on December 27, 2023 the Bermuda Corporate Income Tax Act 2023 (“CITA 2023”) became law.  Subsequent to this date, a list of frequently asked questions (FAQs) has been released with an updated version including additional guidance.  Consistent with the three prior public consultations issued in 2023 on this subject, a 15% corporate income tax (CIT) will be applicable to Bermuda businesses that are part of multinational enterprise (MNE) groups with annual revenue of €750M or more.  The CIT is effective in 2025.

One of the primary policy underpinnings associated with the CIT is alignment with the Global Anti-Base Erosion (GloBE) rules and qualification as a Covered Tax. However, Bermuda currently has no proposals to introduce the Income Inclusion Rule (IIR) or the Undertaxed Profits Rule (UTPR). 

Historically, Bermuda had not imposed taxes on profits, income, dividends, or capital gains.   Bermuda businesses that are not within the scope of the newly enacted Bermuda CIT which is effective in 2025 will continue to not be subject to income tax in Bermuda.