Bermuda: Consultation on proposed amendments to corporate income tax regulations, draft tax credit regulations
Consultation closes June 3, 2026.
The Bermuda Corporate Income Tax Agency (CITA) has released a consultation paper on proposed amendments to the Corporate Income Tax (Administrative) Regulations 2025 and draft regulations under the Tax Credits Act 2025 (TCA). The consultation closes on June 3, 2026.
Proposed amendments to corporate income tax regulations
The consultation paper summarizes a number of proposed amendments to the corporate income tax administrative regulations, primarily related to the determination of interest on underpayments or overpayments of corporate income tax. Overall, it does not appear that the proposed revisions have a significant impact on the underlying framework or structure of the corporate income tax administrative regulations.
The government introduced a requirement for Bermuda constituent entities (CEs) to file Form 001 in connection with corporate income tax installments (read TaxNewsFlash), and has signaled its intention in the consultation paper to increase the fixed penalty for non‑filing (or late filing) of Form 001.
Draft regulations under TCA
The draft regulations under the TCA are designed to mirror the existing corporate income tax administrative regime in most respects. The key distinction is that the TCA regime applies not only to Bermuda constituent entities (BCEs) that are corporate income taxpayers, but also to non‑BCE entities that may be eligible to claim Bermuda tax credits. Aside from this broader scope, the procedures and timelines proposed under the TCA closely align with those for CIT. For example:
- Claimants would be required to register via the CITA online portal, but entities already registered for corporate income tax would generally not need to reregister.
- Groups would need to appoint a single filing entity for TCA purposes (failing which CITA could designate one).
- Tax credit claims would typically be due by the end of the 10th month following the fiscal year (e.g., October 31, 2026, for a December 31, 2025, year-end).
- Tax credit claims may be amended within three years of the original due date, or later with CITA’s consent or during an inquiry.
- Record‑keeping obligations (a minimum five‑year document retention period), CITA’s enquiry powers, and the general four‑year statute of limitations (subject to extension and anti‑avoidance) are all drafted to operate in a manner that clearly aligns with the corporate income tax administrative rules.
For more information, contact a KPMG tax professional in Bermuda:
Will McCallum | willmccallum@kpmg.bm
Jay Payne | jaypayne@kpmg.bm
Sarah Robey | sarahrobey@kpmg.bm
Irina Razumovskaya | irinarazumovskaya@kpmg.bm