The Government of Bermuda, on 15 November, issued its third public consultation paper (PCP), including draft legislation, proposing a 15% corporate income tax (CIT) applicable to Bermuda tax-resident entities and permanent establishments that are part of multinational enterprise (MNE) groups with annual revenue of at least €750M. The tax would be effective beginning in 2025.
Consistent with the first and second public consultations, one of the primary policy underpinnings associated with the CIT, as reflected in the third PCP, 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).
Comments with respect to the third PCP have been requested by 30 November 2023. The Bermuda Government intends to table the CIT bill for debate with a view to enactment prior to 31 December 2023.