Bermuda

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

The Bermuda Corporate Income Tax Act 2023 (CITA 2023) became law on 27 December 2023. This applies a 15% corporate income tax (CIT) to Bermuda businesses that are part of an MNE group with annual revenue of EUR 750 million or more beginning in 2025.

The taxable income for Bermuda CIT is based on book income (similar to the GLoBE rules) with adjustments for certain transactions, such as creditable foreign taxes and the Economic Transition Adjustment (ETA).

Bermuda businesses that are not within the scope of the newly enacted Bermuda CIT 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 applies notwithstanding the existence of previously issued Tax Assurance Certificates for Bermuda businesses that are within the scope of being subject to Bermuda CIT.

See details on exempted companies in the Other issues section.