Form a Bermuda Exempted Company under the Companies Act 1981 and operate from the premium offshore reputation for insurance, reinsurance, funds, and treasury structures. Exempted companies outside Pillar Two scope pay 0% corporate tax; multinationals above EUR 750M consolidated revenue pay 15% QDMTT under the Corporate Income Tax Act 2023 from 1 January 2025.
When Bermuda is the right call, and when it is not.
Bermuda is the largest captive insurance domicile globally and the world's leading catastrophe reinsurance market, holding around 35% of global reinsurance capacity. The Bermuda Monetary Authority Class 1 to Class 4 framework, Solvency II equivalence, and a deep pool of underwriters and actuarial talent make Bermuda the default for cat reinsurance, ILS, and rated reinsurance startups (Conduit Re, Vantage, RenaissanceRe, Hiscox).
The Investment Funds Act 2006 supports open ended, closed ended, segregated account, and incorporated cell company funds. Bermuda Stock Exchange (BSX) listings cover tokenised securities, alternative funds, ETFs, and ILS. The Limited Partnership Act 2024 reform aligned LP structures with Cayman and Delaware VC and PE practice, supporting GP, LP, and carry vehicles for multi billion AUM managers.
The Bermuda Corporate Income Tax Act 2023 enacted a 15% qualified domestic minimum top up tax (QDMTT) from 1 January 2025 for in scope multinational enterprises (groups above EUR 750M consolidated revenue per OECD Pillar Two). Smaller exempted companies stay at 0% CIT. For large multinationals the regime is GloBE compliant, ending Bermuda's reputation as a Pillar Two outlier.
Bermuda has the highest annual maintenance fees in the offshore market: government fees start at USD 2,090 per year for share capital under USD 12,000 and rise to USD 31,200 for share capital above USD 500M. Registered office, Bermuda resident representative, and BMA supervision fees push annual total cost well above USD 8,000 even for a passive holding. Premium reputation comes at premium price.
The Economic Substance Act 2018 (last amended 2024) imposes substance tests for relevant activities including holding entities. Pillar Two QDMTT applies to in scope groups from 2025 with full GloBE Information Return reporting. The BMA exercises active supervision of regulated entities. For light touch structures pick Anguilla, Seychelles, or Belize.
Working data for Bermuda. Cite check each figure before use.
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Each rate, threshold, and deadline below is cited from an authoritative source.
Information is provided for general guidance and reflects tax year 2025 unless noted. Specific situations require advice from a local practitioner. Always confirm against the cited tax authority and registrar before relying on a figure.