Today the Government of Bermuda issued a third consultation paper relating to the administration of the Corporate Income Tax Act 2023, as amended, (the “Principal Act. This consultation paper which is a follow on to the one previously issued on January 31st, addresses the broader administrative provisions relating to the timing of tax payments, returns, and other matters. An illustrative draft bill is included for reference.
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 make relevant adjustments before transitioning into the new Corporate Income Tax regime in Bermuda.
This Third Public Consultation period will run from February 17th to March 10, 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.