RG Business

All eyes on Tax Reform Commission

Corporate income tax estimates raise hopes of tax cuts
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In photo: The Government of Bermuda 2024-2025 Budget – David Burt the Premier, whose Budget statement raised hopes for tax cuts in the coming years scaled (Photograph by Akil Simmons)

After years of increasing costs, the outlook for Bermuda’s local business community brightened in the first quarter with the increasingly realistic prospect that at least some costs could start to fall over the next two years.

The reason is the imminent corporate income tax (CIT): the first estimate of what it will add to government coffers came in David Burt’s Budget statement in February — “at least $750 million a year”, the Premier and finance minister said. That is the equivalent of 60 per cent of the Government’s revenue estimate for 2024-25. Such a boost would create considerable opportunities for cutting taxes.

With CIT funds expected to flow in from July 2025, Mr Burt floated ideas including seeding a new health insurance fund with capital to support implementation of universal healthcare and cutting duty on fuel, food and construction items in the next fiscal year. And by 2026-27, he suggested employer payroll tax could be reduced.

The good news is there is little sign of a vanishing tax advantage sparking an exodus of international companies of economic substance, although much attention this year will be focused on the nature and size of qualified refundable tax credits, which will be critical to domicile decisions being considered in boardrooms.

The Government has signalled that companies within scope of the CIT will no likely no longer pay the employer’s share of payroll tax.

How the impact pans out will depend heavily on the ongoing work of the Tax Reform Commission. Led by Darren Johnston, the TRC has been tasked with making recommendations on tax credits, revisions to the tax system, how CIT funds should be spent for the community’s benefit, and legislative or constitutional guardrails (perhaps to ensure that a certain proportion of the money pays down debt or tops up the underfunded Contributory Pension Fund).

The deadline for the TRC’s final recommendations is the end of October this year.

It all seems too good to be true, and ironic, that Bermuda appears set to benefit enormously from a global minimum tax regime designed by large countries to effectively drive business away from offshore financial centres.

The new rules, the result of an Organisation for Economic Cooperation and Development initiative, require multinationals with revenue over 750 million euros ($815 million) to pay a rate of at least 15 per cent by allowing governments to apply a top-up tax on revenues earned in countries with lower rates.

Could the CIT prove to be a fiscal and economic lifeline? Only time will tell.

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One of the reasons why Bermuda’s international re/insurers are not looking to take flight at the first sign of a tax on profits is that the island is a genuine global hub for the industry with a cluster of world-leading talent and regulation that meets the highest international standards.

A powerful reminder of that was the third Bermuda Risk Summit in March. The Bermuda Business Development Agency event attracted more than 450 delegates, 40 per cent of them from overseas, including re/insurance executives, regulators, risk managers from companies including Amazon, and industry media.

The BDA estimated that the event generated around $3.4 million in economic activity, supporting 432 jobs. But as the BDA observed: “Far more significant were the long-term economic benefits brought about by the additional visitors who flew to Bermuda for business meetings during the week of the summit.”

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