Corporate Income Tax in Bermuda

The Government of Bermuda issued a third Public Consultation Paper on the introduction of a corporate income tax (“CIT”) applicable to Bermuda businesses that are part of a Multinational Enterprise Group (“MNE”) with annual revenue of €750M or more.

The Government conducted two previous Public Consultations concerning the introduction of a CIT in 2023, in August, and October, respectively.

Bermuda aims to minimize Top-Up taxes levied on Bermuda MNEs in other jurisdictions where they operate. The CIT 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% and is developing a robust package of Qualified Refundable Tax Credits (QRTCs) to maintain Bermuda’s attractiveness.

This Consultation Paper includes Illustrative Draft CIT Legislation. Final legislation is expected to be debated in the House of Assembly in December 2023.

Premier and Minister of Finance, the Hon. David Burt JP, MP said, “The introduction of the Corporate Income Tax, which will only apply to large multinational corporations, in parallel with the work of our newly empaneled Tax Reform Commission, will allow the Government to fulfill its commitment to reduce the cost of living and doing business in Bermuda, benefitting both Bermuda's residents and businesses."

The third consultation period begins on November 15, 2023. All comments should be submitted prior to the deadline of November 30, 2023.

Media Contact: Honey S. Adams, hsadams@gov.bm

Consultation Feedback: Collin J. Anderson, cjanderson@gov.bm