Allocation of Taxes Between Constituent Entities

The Corporate Income Tax Amendment (No. 2) Act 2025 repealed and replaced section 18 of the “Corporate Income Tax Act 2023 (“CIT Act”).  As a result of this change, section 18 includes additional circumstances in which adjusted creditable foreign taxes will be allocated to or from a Bermuda Constituent Entity. Pursuant to regulation 10(4) of the Corporate Income Tax (Administrative) Amendment Regulations 2025, the Corporate Income Tax Agency (“CITA” or “the Agency”) is prescribing this guidance regarding the method for determining the amount of adjusted creditable foreign taxes to be allocated to or from a Bermuda Constituent Entity Group. 

This guidance provides details of the computation of the amounts of adjusted creditable foreign taxes to be allocated to or from a Bermuda Constituent Entity.