Bermuda Parliament Passes Bill to Approve Corporate Income Tax Amendment (No. 2) Act 2025

The Bermudian Parliament Dec. 10 passed a bill to approve Corporate Income Tax Amendment (No. 2) Act 2025. The bill includes measures to: 1) amend definitions in accordance with the OECD Pillar Two Global Anti-Base Erosion (GloBE) Model Rules and related guidance; 2) clarify that a shock tax loss carryforward deduction can’t exceed 100 percent of the positive amount; 3) clarify that only foreign tax credits are relevant for tax calculation purposes; 4) revise the computation and allocation of adjusted creditable foreign taxes; 5) revise the methods for adjusting taxable income, including the treatment of tax credits and pension expenses; ...