The world has witnessed some major changes to tax laws and reporting requirements dating back to a few years before the pandemic, but governments ultimately need to ensure their tax systems are simple, fair and reliable.

With the pandemic, natural disasters and wars depleting many government coffers, this article explores developments in international taxation most pertinent to the private wealth sector, with a comparative Bermuda perspective.


The most significant reform of taxation internationally is the Organisation for Economic Co-operation and Development (OECD) agreement ensuring the world’s largest and most profitable multinational enterprises (MNEs) will be subject to a minimum 15% tax rate. Finalised in late 2021, the landmark regime culminates years of intensive negotiation aimed at combatting tax avoidance in a digitalised and globalised world. The multilateral agreement is scheduled for signing this year by 136 jurisdictions representing more than 90% of global GDP, including all OECD and G20 members, for effective implementation in 2023.

The OECD initiative will effectively reallocate more than USD125 billion of profits from about 100 of the world’s leading MNEs to countries worldwide, ensuring they pay a fair share of tax on global revenue exceeding EUR750 million (USD788 million) to wherever they operate and generate profits. This will be achieved by reallocating taxing rights over MNEs from their home countries to markets where they operate and earn profits, regardless of whether they have a physical presence.


Ashley Fife
Counsel at Carey Olsen Bermuda and Chairman of the Bermuda branch of the Society of Trust and Estate Practitioners
Tel: +1 441 542 4514

To help pay for the enormous costs of tackling the global pandemic, the International Monetary Fund (IMF) has recommended governments consider levying higher taxes on the income and wealth of the rich, at least temporarily, and particularly on property, capital gains and inheritance.

On the flip side, many governments, including Bermuda, appear to remain mindful of the potentially adverse impact that imposing new or higher taxes may have on their economies when certain economic sectors have been significantly stifled. In Bermuda, the pandemic has had considerably less of a financial impact on the financial services sector than the tourism or retail sectors. However, the IMF projects Bermuda’s economy to bounce back to its 2019 level by the end of 2022.


Many governments are carefully assessing the ongoing success of stimulus measures and need for relief measures, and the extent to which revenues may need to be supplemented by new or higher taxes. Rather than focus on introducing new and higher taxes, many jurisdictions have focused on implementing measures to stimulate their economies and provide temporary relief measures to most affected sectors and individuals.

Leveraging several initiatives during the crisis, Bermuda has fortunately been able to attract people and consequently generate government fees, customs duties and other revenue. For example, a “digital nomad visa” was introduced enabling people to work remotely for an employer outside of Bermuda for a year, with the possibility of renewal.

Bermuda’s economic investment certificate (EIC), meanwhile, permits residence and employment in Bermuda for five years for anyone making an upfront “qualifying investment” of USD2.5 million (including real estate and donations to Bermuda registered charities). It also enables the holder’s spouse or dependents to reside in Bermuda during that time, and the EIC holder additionally has the prospect of applying for a residential certificate upon expiration, for indefinite residence of the holder, spouse and dependents.

While the government has made some minor increases to stamp duties on real estate and payroll taxes, Bermuda has also provided payroll tax relief measures for certain businesses, decreased transport infrastructure taxes to relieve the tourism industry, and enabled ability of individuals to access levels of funds from certain regulated pension schemes before retirement.

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The author would like to thank Gina Pereira, Co-Managing Director of Meritus Trust Company, for her valuable input to this article

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