Offshore Common Law
Pillar Two compliant multinational groups, Bermuda
Bermuda enacted a Corporate Income Tax Act in 2023 with effect from 1 January 2025, applying a 15% qualified domestic minimum top up tax (QDMTT) only to in scope multinational enterprises (EUR 750M+ consolidated revenue per OECD Pillar Two). Smaller exempted companies remain at 0% CIT. The regime is GloBE compliant and locks Bermuda into the OECD framework.
15% QDMTT from 2025EUR 750M scope onlyOECD GloBE compliant
Start setup {placement} 4 min · no card required
Corp tax
15%
Fastest setup
10 days
Tax treaties
41
Region
Offshore
What you'll need
- No resident director required
- Local registered office required
- Economic-substance test applies
- Minimum capital: USD 1
- Administrative language: English
- Legal system: Common law
Tax and treaty profile
- Corporate tax 15%
- Tax treaties 41
- VAT rate 0%
- Withholding on dividends 0%
Key treaty partners
United States (TIEA)United KingdomCanadaAustraliaJapanGermany
Banking and payments
- Banking takes 2 to 4 weeks with KYC
- Stripe not supported
- Crypto banking available
- EMI license framework available
Considerations
If you are a cost sensitive solo operator
Bermuda is the most expensive offshore jurisdiction by annual maintenance: government fees scale by share capital and start around USD 2,090 per year for share capital under USD 12,000, rising to USD 31,200 for share capital above USD 500M. Registered agent and director fees are also at the top of the offshore market. For a simple holding structure consider:
High annual feesPremium agent feesHeavy compliance for small caps