CITA releases corporate income tax return forms and filing instructions

The CIT return is due on the last day of the 10th month following the end of the fiscal year to which the return relates, subject to adjustment where that day is not a business day in Bermuda. The 2025 return will be due 2 November 2026 for calendar year taxpayers.

Bermuda constituent entity (BCE) groups (comprising one or more BCEs of an in-scope multinational enterprise (MNE) group) are required to file a CIT return for each fiscal year beginning on or after 1 January 2025. Each CIT return filing comprises the CIT online return and either the simplified CIT return schedules (to the extent that the BCE group is a qualifying de minimis BCE group that meets the requirements described in the simplified CIT return schedule instructions, and the filing BCE has chosen to file those schedules) or the standard CIT return schedules (in all other cases).

The standard CIT return schedules are expected to be relevant for most in-scope taxpayers that do not qualify for, or do not elect to use, the simplified return process. The instructions state that the standard CIT return schedules are intended to support the determination of the aggregated amounts required to be reported in the CIT online return and to provide the CITA with further information regarding the derivation of those amounts.

As a summary, the following forms and instructions were released:

Some key takeaways are highlighted below, followed by an overview of the standard CIT return schedules and some other key considerations.

• The CIT return filing process includes both an online filing component and Excel-based schedules. The relevant schedules must be uploaded to the CIT online return before submission. 
• A BCE group should file either the simplified CIT return schedules or the standard CIT return schedules for a fiscal year, but not both.
• The simplified CIT return schedules are available only where specific requirements are met, including making the de minimis exemption election, electing not to apply the economic transition adjustment provisions, electing to disregard opening tax loss carryforwards and specified loss amounts, and having no tax payments or distributable tax credit benefits applied to BCE members of the BCE group for the fiscal year.
• The standard CIT return schedules include seven schedules covering group information, the CIT calculation, taxable adjustments, tax loss carryforwards, foreign tax credits, installment underpayment interest, and additional election information. 
• The instructions emphasize the need for consistency between the CIT online return and the uploaded schedules. If the CIT online return is not accompanied by the appropriate primary schedules, or if the schedules are inaccurate, incomplete, or inconsistent with the online return, the CITA may treat the return filing requirement as not having been satisfied. 
• Penalties and interest may apply until the CITA is satisfied that the filing requirement has been met through the submission of accurate and complete primary schedules. 
• Certain taxpayers may also need to consider completing secondary schedules or providing additional supporting documentation. The standard CIT return schedules instructions identify secondary schedules for opening tax loss carryforwards and creditable foreign tax allocations, where applicable. 
• The instructions include detailed election procedures. In general, elections must be made in the relevant CIT return schedules by selecting the applicable option in the relevant election item.
  

Other key considerations

• Taxpayers should review CITA Online to confirm that all BCE members have been registered and assigned taxpayer identification numbers (TINs) before preparing and submitting the CIT return.
• Taxpayers should confirm that the BCE group composition, CIT group TIN, filing BCE/controller designation, and fiscal year information are correct in CITA Online.
• Groups intending to rely on the de minimis exemption should confirm that all relevant requirements are met and that the appropriate simplified filing materials are used.
• Groups with opening tax loss carryforwards or foreign tax credit allocations should consider whether secondary schedules may be required to support the amounts reported in the CIT return.