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Double-taxation clarification

A story on Bermuda’s double taxation agreement (DTA) with Bahrain last Friday stated that Bermuda had negotiated a double taxation agreement with Canada, as part of the tax information exchange agreement (TIEA) agreed with that country. The Finance Ministry has asked us to clarify that under the terms of the TIEA negotiated with Canada, dividends of foreign affiliates that are resident in Bermuda that are paid to their Canadian parent companies out of the active business income earned in Bermuda will be exempt from Canadian taxation. Although this will extend an important benefit to Bermuda that had previously been conferred only to countries with which Canada has a double tax treaty in force, there is no DTA agreed with Canada.