Bermuda’s Plans For a Global Minimum Tax

In Bermuda’s 2023 Budget last week, the government has announced it is actively looking at how to implement the Pillar Two global minimum tax and that Bermuda could reap significant revenue benefits. 

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Private Equity Fund Structure

Cross-Border Deals After Pillar Two

In this article we look at some of the most significant issues to consider including the determination of when and how deals can bring groups within the scope of Pillar Two, specific considerations for private equity funds, differences in GloBE and domestic tax treatment and potential restrictions on post-acquisition transfers. 

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