Corporate Income Tax Administrative Provisions
Today the Government of Bermuda issued a public consultation paper “intended to provide Bermuda stakeholders with a preliminary, high-level summary of the proposed taxpayer compliance framework [the “Administrative Provisions”] and to obtain public feedback on the proposals.”
A Government spokesperson said, “The Corporate Income Tax Act 2023 [the “Principal Act”] was enacted in December 2023 and provides that Bermuda Constituent Entity Groups [“BCE Groups”], comprised of one or more Bermuda Constituent Entities [“BCEs”] of an In-Scope MNE Group, are subject to Bermuda corporate income tax [“CIT”] concerning fiscal years beginning on or after January 1, 2025. In addition to the various technical provisions relevant to the determination of the CIT liability of a BCE Group, the Principal Act introduced the concept of a Bermuda CIT return to be filed by a Filing BCE on behalf of a BCE Group.
“The CIT will become effective in 2025, providing MNEs the necessary time to adjust their systems as they transition to paying a corporate income tax in Bermuda.
“We appreciate the feedback received from previous consultation periods, and directly from industry leaders, and I am confident that our new CIT regime represents an attractive path forward for Bermuda that is in line with international tax rules,” said Premier and Finance Minister David Burt.
“The Administrative Provisions aim to balance effective tax collection with minimizing administration and taxpayer compliance costs.
“The Government of Bermuda, through the Ministry of Finance will continue to collaborate with all stakeholders to ensure that Bermuda remains an effective and cooperative partner in addressing global tax matters.”
“This First Public Consultation period will run until September 4, 2024. Submissions received after this date may not be considered. It is proposed that there will be a second Public Consultation later in the year enclosing draft legislation incorporating the results of this Public Consultation for further comment.
“Consultation Paper Responses and Comments should be submitted by email to: FINANCE@gov.bm. Respondents should include “Corporate Income Tax Administration” in the subject line.
“The Government welcomes feedback from all stakeholders on these proposals, including comments and suggestions for improvements.”
The full Introduction of Corporate Income Tax Administrative Provisions here [PDF].
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