Log In

Reset Password

Tax regime attracting cruise lines to Bermuda

Home port: Carnival is the latest cruise line to move its corporate domicile to Bermuda (File photograph by Blaire Simmons)

Carnival has received shareholder approval for its corporate restructuring and the company’s redomiciliation to Bermuda – paving the way for another cruise line giant to move to the island.

Norwegian Cruise Line, Viking and Virgin Voyages are among other major cruise lines based on the island. And according to a local shipping lawyer, Bermuda’s corporate income tax regime is part of the attraction.

Carnival’s plans involve scrapping the company’s dual-listing structure, unifying Carnival Corporation and Carnival plc, and also shifting the domicile of Carnival Corporation from Panama to Bermuda.

The move is aimed at simplifying the company’s corporate structure, while the move to Bermuda bases Carnival in a jurisdiction that is “widely recognised and aligned with international financial standards”.

The shareholder meetings were held on April 17 and the results were reported in a filing with the US Securities and Exchange Commission on Monday.

Victor Richards, Conyers director (Photograph supplied)

The introduction of the global minimum tax, under the Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting Pillar 2 initiative, led to Bermuda implementing a 15 per cent corporate income tax that took effect last year. The tax applies to multinational corporations with global revenue of €750 million (about $878 million) or more.

While this aligns Bermuda with international taxation standards, the CIT regime also includes an exclusion for international shipping income, which makes up the vast majority of cruise lines’ business.

Victor Richards, a director in Conyers’ Bermuda corporate practice, said this combination is at the heart of the island’s attraction.

“The legislative framework allows corporations to qualify for an exclusion from corporate tax on international shipping income, provided they can demonstrate that the strategic management and decision-making regarding their vessels take place within Bermuda,” Mr Richards said.

“These provisions have proven especially attractive to cruise companies seeking both operational flexibility and tax efficiency.

“In addition to the CIT Act, Bermuda is widely recognised as a first-class jurisdiction to do business, known for its stable English common law system, close proximity to the US and Europe and its robust regulatory environment and modern infrastructure.”

Satisfying the strategic management condition requirement could mean in practice making major capital decisions such as the buying and selling of ships, holding board meetings here, and having an office in Bermuda where such decisions are made.

Not all of the cruise lines’ corporate structures are the same. For example, Carnival, after its restructuring, will be tax resident in the UK, while NCL is tax resident in Bermuda.

Bermuda’s attraction to maritime businesses is not confined to cruise lines, Mr Richards said.

“Other sectors within the shipping industry have also moved their corporate entities from jurisdictions such as the Marshall Islands to Bermuda, seeking to be domiciled in an internationally recognised business jurisdiction and benefit from the Corporate Income Tax Act,” he said.

“This broader migration underscores Bermuda’s growing influence as a global centre for shipping and maritime corporate structures, driven by its robust regulatory framework and alignment with international tax standards.”

Royal Gazette has implemented platform upgrades, requiring users to utilize their Royal Gazette Account Login to comment on Disqus for enhanced security. To create an account, click here.

You must be Registered or to post comment or to vote.

Published April 23, 2026 at 8:00 am (Updated April 23, 2026 at 7:26 am)

Tax regime attracting cruise lines to Bermuda

Users agree to adhere to our Online User Conduct for commenting and user who violate the Terms of Service will be banned.