Key Takeaways
- Bermuda's Office of the Tax Commissioner administers taxes and carries defined statutory duties for taxpayers and employers.
- A new corporate income tax agency reflects Bermuda's shifting tax landscape that non-resident owners should monitor.
- Registering as a taxpayer or employer, using the online portals and tracking the filing and payment calendar keeps obligations current.
- Assessment, audit and investigation powers sit alongside penalties and interest, so timely and accurate filing reduces enforcement risk.
Meet the Office of the Tax Commissioner: Bermuda's Revenue Administrator
The tax authority in Bermuda is split between two bodies, not one. Domestic taxes fall to the Office of the Tax Commissioner, while a newer agency handles corporate income tax and international reporting.
For a foreign owner, this division matters from the outset. The Office of the Tax Commissioner (OTC) collects Payroll Tax, Land Tax, and Stamp Duty, and it administers the obligations most foreign-owned employers will encounter on the ground.
This article explains who each authority is, what each administers, how registration and filing work, and where the enforcement powers sit. It is written for non-resident business owners and their advisers deciding whether to incorporate in or stay compliant with the jurisdiction.
What the Tax Commissioner Administers and Its Statutory Role
The OTC's job is to collect taxes and duties under the legislation that assigns them to it. Its stated values are professionalism, integrity, confidentiality, and cooperation, and it runs the government's online filing system alongside taxpayer guides and quarterly filing seminars.
Three main charges sit with this office. Payroll Tax operates under the Payroll Tax Act 1995 and the Payroll Tax Rates Act 1995, Stamp Duty (including estate tax collected through it) under the Stamp Duties Act 1975, and Land Tax on all developed real property.
There is no personal income tax. Rather than tax individuals on income, the system assesses Payroll Tax on employers, which reshapes how a foreign-owned firm budgets for staff costs.
The office keeps the full record behind each taxpayer: registrations, returns, assessments, instruments, and correspondence. Bermuda's fiscal year runs 1 April through 31 March, a date to fix in your planning before any filing question arises.
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The New Corporate Income Tax Agency and Bermuda's Shifting Tax Landscape
A second authority now exists for corporate income tax. The Corporate Income Tax Agency (CITA) was established by the Corporate Income Tax Agency Act 2024 to administer a regime introduced under the Corporate Income Tax Act 2023, which became law on 27 December 2023.
The tax it administers is narrow in reach. A 15% corporate income tax applies to entities that form part of a multinational group with annual revenue of EUR 750 million or more, taking effect from 2025; firms below that threshold keep their position of no income tax liability.
Bermuda's rules borrow foundational definitions from the OECD's Pillar Two GloBE model but depart from them. The framework does not adopt the Income Inclusion Rule or the Undertaxed Profits Rule, and the charge is not expected to operate as a Qualified Domestic Minimum Top-Up Tax.
The arrival of this tax disturbs a long-standing comfort for in-scope groups. The government has issued Tax Assurance Certificates to exempted undertakings through the Bermuda Monetary Authority, promising no such tax until 31 March 2035, but the corporate income tax applies regardless of any certificate held by an entity within its scope.
CITA's remit reaches beyond the new tax. It has taken over Economic Substance and the Automatic Exchange of Information, functions transferred from the Registrar of Companies as better suited to a dedicated tax body.
The OTC governs Payroll Tax, Land Tax, and Stamp Duty; CITA governs corporate income tax, Economic Substance declarations, CRS, FATCA, and Country-by-Country Reporting. Advisers must track filings with both.
Further changes have followed in close succession. The Economic Substance Amendment Act 2026 and accompanying regulations were enacted on 31 March 2026, and from 13 March 2026 the Minister of Finance designated CITA as the Competent Authority under the International Cooperation (Tax Information Exchange Agreements) Act 2005 and the U.S.A.–Bermuda Tax Convention Act 1986.
Registering as a Taxpayer or Employer with the Authority
Registration depends on which obligation you trigger. A foreign-owned entity that hires staff in the jurisdiction registers with the OTC; a group caught by the corporate income tax registers separately with CITA.
For Payroll Tax, the timing is strict. Every employer and self-employed person liable for the tax must register within 7 days of the end of the first tax period in which business commences, and failure to do so is a criminal offence.
That duty is not limited to local employers. Foreign contractors, sub-contractors, and professionals supplying services on a contract or fee basis also have to register and pay Payroll Tax.
Corporate income tax registration follows a different track and applies only to in-scope groups. Existing Bermuda Constituent Entities were required to register with CITA by 31 March 2025 through the Bermuda Tax Portal, where each receives a Taxpayer Identification Number.
The deadlines under the final Administrative Regulations turn on filing roles:
- The Filing entity must register no later than 10 days before any required instalment payment.
- All other constituent entities must register no later than 90 days before the original due date of the first return.
- Registration requires detail on the wider group, including the Ultimate Parent Entity and the Filing entity.
Whether certain entities outside the constituent-entity definition must also register remains under review, including groups with a limited international footprint, excluded entities, and entities held less than 80%.
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Online Services, Portals and Electronic Filing
Filing in the jurisdiction is electronic, and each authority runs its own system. The OTC's eTax service at www.etax.gov.bm operates around the clock for domestic tax filing and payment.
Online filing is mandatory for some employers. All exempted companies, and any company with annual remuneration above $200,000, must submit Payroll Tax through eTax, which accepts VISA, Mastercard, and American Express.
| Obligation | Authority | Portal |
|---|---|---|
| Payroll Tax, Land Tax | OTC | www.etax.gov.bm |
| Corporate income tax registration and filings | CITA | www.cita.bm |
| CRS and Country-by-Country reports | CITA-administered | https://bdaaeoi.bm |
Land Tax may also be settled through internet banking with the Bank of Bermuda (HSBC) and the Bank of N.T. Butterfield. CITA Online handles corporate income tax registration, instalment disclosures, and edits to group composition, and CITA released Form 001 on 16 January 2026 for reporting instalment computation details, with a first due date of 2 February 2026 for many groups.
The Filing and Payment Calendar You Need to Track
Payroll Tax falls due quarterly. Payments are made on 15 January, 15 April, 15 July, and 15 October, with a 15-day grace period; late filers face penalties and assessments.
Corporate income tax runs on its own instalment cycle tied to the fiscal year:
- First instalment (Tax Estimate): last day of the 8th month of the fiscal year, being 31 August 2025 for calendar-year taxpayers.
- Second instalment: 15th day of the 12th month, being 15 December 2025 for calendar-year taxpayers.
- Annual return: 15th day of the 10th month following fiscal year-end, so 15 October for calendar-year groups.
A deadline landing on a weekend or public holiday rolls to the next business day. Among the instalment dates ahead are 16 June 2026 (second instalment for a 30 June 2026 year-end) and 30 June 2026 (first instalment for a 31 October 2026 year-end).
International reporting carries its own dates. Economic Substance Declaration Forms are due within six months of the financial year-end, giving a 31 December 2025 year-end a deadline of 30 June 2026; CRS returns for the 2025 reporting year are due by 31 May 2026, and the Annual CRS Compliance Certification Form by 30 September 2026.
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Assessment, Audit and Investigation Powers
CITA holds defined powers over corporate income tax returns. It may open an enquiry into a return until the later of three years after the filing date or the date the return was actually filed, and that window can be extended by mutual agreement.
Record-keeping underpins those powers. Supporting records must be kept for seven years from the filing date, and failure to retain them may attract penalties.
On Economic Substance, the 2026 amendments moved the Registrar's former powers to CITA. The agency can inspect during working hours on reasonable notice, and an entity receiving a warning notice may make written representations within a period of not less than 28 days.
A decision then follows a set sequence. CITA must determine within three months whether to impose a penalty, issue a decision notice, and that notice may be appealed to the Supreme Court; knowingly supplying false information or obstructing the agency can bring criminal fines, imprisonment, or both.
For Payroll Tax, the OTC's detailed audit procedure is not set out publicly. As a general matter, a domestic tax authority can inspect employer records and assess under-declared remuneration.
Penalties, Interest and Enforcement Measures
Late or underpaid Payroll Tax draws penalties and assessments. A separate penalty applies where an employer fails to file in the required electronic format when e-filing is mandatory.
Corporate income tax penalties are more precisely codified. Under the Corporate Income Tax Amendment (No. 2) Act 2025, failure to file required information or documentation other than a return carries a civil penalty of USD $1,000 for each month or part-month past the deadline, and the same charge applies to a failure to file Form 001.
Interest runs on underpaid instalments under the regulations. Civil penalties for late returns may be fixed over time, geared to the tax, or a combination, and failure to file a return generally results in assessed penalties or sanctions.
Missing CRS deadlines can also trigger penalties.
Contacting the Authority: Offices and Communication Channels
The OTC keeps a physical presence in the capital. Its office sits at the F.B. Perry Building, 1st Floor, 40 Church Street, Hamilton HM 12, with a mailing address at P.O. Box HM 1374, Hamilton HM FX.
General eTax queries reach the office at etax@gov.bm, and its filing portal is www.etax.gov.bm.
CITA operates primarily online through www.cita.bm. Its dedicated support address for AEOI and CRS matters is exchangesupport@cita.bm, effective March 2026, replacing the earlier address that is no longer active; CRS and Country-by-Country reports are filed at https://bdaaeoi.bm. No general CITA telephone number or office address is published through official sources.
What This Means for a Non-Resident Owner or Adviser
For most foreign-owned companies, the headline is favourable. A firm below the EUR 750 million multinational revenue threshold faces no corporate income tax, and non-residents are not subject to withholding on dividends, interest, or royalties.
The real obligation arises from employment. With no personal income tax, the principal duty is Payroll Tax on employers, and a foreign entity that hires staff must register with the OTC within 7 days of the end of its first tax period or commit a criminal offence.
Service providers are not exempt. Foreign contractors and professionals rendering services on a contract or fee basis must register and pay Payroll Tax in the same way.
In-scope groups face the harder position. Where a Bermuda entity belongs to a multinational group with revenue of EUR 750 million or more, the 15% corporate income tax applies from 1 January 2025, and it overrides any Tax Assurance Certificate the entity holds.
Entities claiming non-resident status under the Economic Substance Act 2018 must now file their Declaration Forms with CITA rather than the Registrar of Companies, following the 2026 amendments.
The practical takeaway is procedural. Two authorities now apply, FATCA and TIEA correspondence routes through CITA as Competent Authority from 13 March 2026, and advisers should map each obligation to the correct body before any deadline arrives.
Conclusion
Bermuda runs its tax administration through two authorities: the Office of the Tax Commissioner for Payroll Tax, Land Tax, and Stamp Duty, and the Corporate Income Tax Agency for the 15% corporate income tax, Economic Substance, and international reporting. A foreign owner below the multinational revenue threshold still faces no corporate or personal income tax, but the Payroll Tax registration duty for employers and contractors is real and carries criminal exposure if missed. Large groups within the corporate income tax net must treat the regime as live, since it displaces older exemption certificates. Knowing which body owns which obligation, and meeting each calendar date, is the core of staying compliant here.
How Expanship Can Help Your Business in Bermuda
Expanship helps foreign owners place each obligation with the right authority, whether that means registering as an employer with the Office of the Tax Commissioner, handling corporate income tax registration with CITA, or keeping Economic Substance and CRS filings on track. The same team supports the wider needs of a non-resident entity from formation through ongoing operation.
- Company formation and structuring for foreign-owned entities
- Registered agent and registered office services
- Tax registration and filing with the OTC and CITA
- Ongoing compliance management across both authorities
- Accounting and bookkeeping aligned to the fiscal year
- Introductions to local banking
To discuss your requirements, contact Expanship Bermuda.
Frequently Asked Questions
There are two. The Office of the Tax Commissioner administers Payroll Tax, Land Tax, and Stamp Duty, while the Corporate Income Tax Agency administers the corporate income tax along with Economic Substance, CRS, FATCA, and Country-by-Country Reporting.
Only if it belongs to a multinational group with annual revenue of EUR 750 million or more, in which case a 15% corporate income tax applies from 1 January 2025. Companies below that threshold continue to have no income tax liability.
Within 7 days of the end of the first tax period in which business commences. Failure to register is a criminal offence, and the duty extends to foreign contractors and professionals providing services on a contract or fee basis.
Filing is electronic. Payroll Tax and Land Tax go through the OTC's eTax portal at www.etax.gov.bm, corporate income tax matters through CITA Online at www.cita.bm, and CRS and Country-by-Country reports through https://bdaaeoi.bm.
For entities within scope of the corporate income tax, the tax applies notwithstanding any certificate held. The certificates otherwise state that future Parliamentary imposition will not apply until 31 March 2035, but that assurance does not shield in-scope multinational groups.
Failure to file required information or documentation other than a return, including Form 001, carries a civil penalty of USD $1,000 for each month or part-month past the deadline. Interest also runs on underpaid instalments, and late returns may attract fixed or tax-geared penalties.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
