Companies caught within the scope of Bermuda’s new corporate income tax regime will likely be required to make at least two periodic payments next year before making their first formal tax filing in the last quarter of 2026, a panellist said today at the Bermuda Captive Conference at the Pier Six complex in Hamilton.

The Corporate Income Tax Act 2023 is to come into full effect on January 1, 2025.

It will apply to Bermudian constituent entities that are members of a multinational enterprise group that has annual revenues of €750 million (about $827 million) or more in the consolidated financial statements of the ultimate parent in at least two of the preceding four fiscal years.

The global minimum tax rate on profit is to be 15 per cent. The corporate income tax regime in Bermuda allows the government to collect taxes from entities that would otherwise pay such tax in other jurisdictions.

Cheryl-Ann Lister OBE, is a senior financial and economic adviser in the Ministry of Finance, and the policy lead on the CIT project.

She said the timing of those payments in 2025 might change, and that government will take into account industry input following the ministry’s next consultation paper on the CIT.

Ms Lister said less than 500 multinational enterprises and less than 2,000 companies are expected to fall within the scope of the CIT.

The number of captives within the scope of the tax will remain unknown until companies complete registration requirements in the first quarter of next year.

Ms Lister appeared on the panel “Fiscal Horizons: Exploring the Effect of Corporate Income Tax in Bermuda”, where she was joined by Crystal Pittendrigh, tax director, PwC Bermuda; Sarah Robey, tax partner, KPMG in Bermuda; and Donay Viljoen, tax, Forvis Mazars in Bermuda.

The moderator was Jennifer Masters, senior vice-president — Bermuda captive leader, Brown and Brown.