Bermuda

Bermuda currently imposes no taxes on profits, income, dividends, or capital gains, has no limit on the accumulation of profit, and has no requirement to distribute dividends.

As discussed in the Significant Developments section, the Bermuda Corporate Income Tax Act 2023 (“CITA 2023”) became law on December 27, 2023.  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.

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.

The Bermuda government has routinely granted Tax Assurance Certificates to exempted undertakings (i.e. exempted companies, permit companies, exempted partnerships, and exempted unit trust schemes) on application to the Minister through the Bermuda Monetary Authority.  These Tax Assurance Certificates state that any future Parliamentary imposition of such taxes will not be applicable to the company and its operations until 31 March 2035.  Of note, the Bermuda CIT disregards the existence of previously issued Tax Assurance Certificates for Bermuda businesses which are within the scope of being subject to Bermuda CIT.

See details on exempted companies in the Other issues section.