In general, there is no corporate tax on income, profits, dividends and capital gains in Bermuda.

However, in December 2023, Bermuda enacted a new corporate tax law introducing corporate tax for taxpayers in Bermuda that fall within the scope of the Pillar 2 global minimum tax (GloBE) rules. The new corporate tax applies to Bermuda resident companies and permanent establishments that are members of an in-scope multinational entity (MNE) group with annual revenue of EUR 750 million or more in at least two out of four immediately preceding fiscal years.

The corporate tax will apply effective 1 January 2025. Entities not in the scope of the newly enacted law will continue to not be subject to corporate tax in Bermuda.

Excluded MNE Groups

An MNE group will be excluded from the scope of application of the new corporate tax if:

The entities forming part of the MNE group are located in five or fewer jurisdictions excluding the reference jurisdiction (i.e., the jurisdiction in which the MNE group’s highest value tangible assets are located during the first fiscal year in which the threshold of EUR 750 million is met);
The sum of the net book values of tangible assets of all entities (excluding entities located in the reference jurisdiction) does not exceed EUR 50 million; and
No parent entity is required to apply an IIR with respect to any Bermuda constituent entity of the MNE group.

The exclusion applies to the first five fiscal years beginning from 1 January 2025 or the first fiscal year when the MNE group meets the threshold of EUR 750 million, whichever is later.

Entities Holding Tax Assurance Certificates

Certain exempted entities (such as exempted companies, permit companies, exempted partnerships, and exempted unit trust schemes) were issued Tax Assurance Certificates, which provide that any future parliamentary imposition of taxes will not be applicable to the company holding the certificate until 31 March 2035. The new Bermuda corporate tax law disregards the existence of previously issued Tax Assurance Certificates for in-scope Bermuda constituent entities that are subject to corporate tax under the new law.

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