Bermuda Gazettes Law Introducing Corporate Income Tax for Calculation in Global Minimum Tax

The Bermudian Official Gazette Dec. 28 published Law No. 35/2023, introducing corporate income tax on domestic businesses that are part of large multinational enterprise (MNE) groups, for consideration in calculating the 15 percent global minimum tax under OECD Pillar 2. The law includes measures: 1) imposing corporate income tax at rates from 9 percent to 15 percent on resident businesses and permanent establishments (PEs) in Bermuda that are part of MNEs with annual global revenue exceeding 750 million euros (US$829.4 million); 2) including key definitions from Chapter 1 of the OECD’s global anti-base erosion (GloBE) rules; 3) excluding specified entities ...