As Bermuda races to implement a 15 per cent minimum corporate tax platform, cracks are appearing in what was thought to be an ironclad agreement for the new, global regime, as proposed by the Organisation for Economic Co-operation and Development.

The Bermuda Government intends to enact a new corporate income tax prior to the end of the month, with an effective date for tax years beginning on or beyond January 1, 2025, based on the OECD initiative.

But it is not the only global tax proposal on the table, with interest in one being developed by the United Nations gaining momentum.

The UN is assembling a multi-governmental committee to establish by August 2024 the terms of reference for a UN framework convention on international tax co-operation.

It is supported by countries unconvinced they can trust the OECD to represent their interests.

The UN recently voted to create its own “historic” global tax convention, despite moves to kill the proposal by Britain and the European Union.

The UN’s General Assembly voted 125 to 48 to develop the global tax framework as proposed by African nations, who demanded a seat at the table in search of a fairer, more resilient, global economy.

The November vote in New York was precipitated by a heated debate, as nine countries abstained from a ballot on drastically changing how global tax rules are set.

The International Consortium of Investigative Journalists reported: “For decades, the OECD — a group of 38 mostly high-income countries that includes the UK and the US — has dominated international tax policy.

“But in recent years criticism over the outsize power wielded by wealthy countries in its closed-door decision-making has grown, including at the top levels of the UN.

Earlier this year, UN secretary-general António Guterres said in a report that enhancing the UN’s role in shaping policy was “the most viable path for making international tax co-operation fully inclusive and more effective.”

Next year, all UN member states will be invited to join the intergovernmental negotiation process.

In a report this year, the Tax Justice Network warned that multinationals and wealthy individuals will continue to use tax havens to whittle down their tax bills, identifying: “four countries among the jurisdictions enabling the loss of public money: the UK, the Netherlands, Luxembourg and Switzerland. All four are also members of the OECD.”

The UN’s tax resolution was initially tabled by Nigeria on behalf of the Africa Group, with one advocate, Action Aid International, hailing it a significant victory, and “the world’s first truly global agreement on international tax co-operation. This marks a truly historic shift – a democratic tax revolution.”

The international non-governmental organisation working against global poverty and injustice noted those opposing were “mainly rich [OECD] countries”.

Arthur Larok, the secretary-general said: “The OECD has set global tax rules mainly benefiting a small group of wealthy countries and former colonisers.”

Meanwhile, the OECD said last month it was proud of its record of achieving consensus-based solutions to address tax evasion and avoidance. A statement pointed out how the OECD global policy forum works with more than 100 countries to promote policies that improve the economic and social wellbeing of people around the world.

It said its groundbreaking international tax agreement will make international tax arrangements fairer and work better in a digitalised and globalised world economy.

The OECD remains committed to completing “this critically important work” and to ensuring the broad and effective implementation of this agreement to “stabilise the international tax system and support developing countries”.

David Burt, the Premier and finance minister, told Parliament that the changes to the global tax system initially placed Bermuda in a precarious position, but with legislation he took to the Lower House on Friday, he said: “in true Bermuda fashion, we adapted to these significant changes and identified ways to maximise the benefit”.

The 15 per cent corporate income statutory tax will be applicable to Bermuda businesses that are part of a multinational group with annual revenue of €750 million (about $808 million) or more.

Mr Burt said: “The corporate income tax legislation will come into force in its entirety in January 2025, which would provide multinational enterprises time to transition and make the necessary adjustments.”

The local changes are a product of consultation with local and international business expertise.

Bermuda would join with 136 countries, representing more than 90 per cent of the global economy.

But even countries that signed up to the OECD plan are having reservations.

Switzerland, for example, has detractors among its legislators. The senate commission for economic affairs and taxation expressed reservations as far back as June, even as a referendum found Swiss voters clearly convinced 4:1 that the OECD had the right idea.