Corporate Income Tax Administrative Provisions
Today the Government issued a “second paper which focuses on certain of the enforcement provisions relating to the administration of the Corporate Income Tax Act 2023, as amended [the Principal Act], which are required under Bermuda law to be enacted by Parliament in statutory form rather than by regulation. ”
A Government spokesperson said, “A further consultation will follow next month to address the broader administrative provisions relating to the timing of tax payments, returns, and other matters.
“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] for fiscal years that began 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 became effective in January 2025, providing MNEs the necessary time to adjust their systems prior to transitioning into the new Corporate Income Tax regime in Bermuda.
Premier and Finance Minister David Burt said, “We are grateful for the insightful and thoughtful responses received during the first public consultation. Careful consideration has been given to many of the observations and, where appropriate, have been incorporated into the draft legislation. Other suggestions are still under review for potential inclusion. Your engagement is invaluable to us.
“The Government of Bermuda, through the Ministry of Finance, remains committed to working closely with all stakeholders. Our goal is to ensure that Bermuda continues to be an effective and cooperative partner in addressing global tax matters. Together, we can uphold our reputation and meet international standards.”
The Government spokesperson said, “This second public consultation period will run from January 31, 2025 to February 21, 2025. Submissions received after this date may not be considered. Consultation paper responses and comments should be submitted by email to finance@gov.bm. Respondents should include ‘Corporate Income Tax Administration’ in the subject box.
“The Government welcomes feedback from all stakeholders on these proposals, including comments and suggestions for improvements.”
The full second public consultation overview follows below [PDF here]:
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