Bermuda Corporate Income Tax: Considerations For Captive Insurers

Key takeaways

• The operating provisions of the corporate income tax regime for Bermuda legislation will be effective for fiscal years beginning on or after 1 January 2025. This will apply to "Bermuda Constituent Entities" of an "In Scope MNE Group", each as defined in the legislation.

• Many captive insurers will not be big enough to fall into scope of the new tax regime. In addition, it is expected that no additional tax liability will need to be paid by US-owned captives in Bermuda that make the 953(d) election – meaning they are subject to US federal income tax.

• Larger captive insurers that falls "in scope" will need to assess tax liability under the new corporate income tax regime and consider any applicable exemptions and tax elections, we set out some of they key considerations in our advisory below.