Bermuda featured in a New York Times investigation of how American multinational companies are using island-based subsidiaries to slash their tax bills — even after implementation of the corporate income tax.

The report examined securities filings from hundreds of public companies and found that many continue to report major tax benefits linked to low-tax jurisdictions, including Bermuda, Malta, Ireland and Switzerland.

The Ministry of Finance rejected the report's broader characterisation of the island as a tax haven.

In response to a query by The Royal Gazette, a spokeswoman for the ministry said: “This characterisation of Bermuda as a tax haven is unfortunate. Bermuda is a member of the [Organisation for Economic Co-operation and Development] inclusive framework and in 2025 introduced a corporate income tax, in full compliance with international tax rules.”

In fact, interviews and recent regulatory filings suggest the Bermuda connection is more nuanced. The island introduced a 15 per cent corporate income tax on certain multinational enterprises at the start of 2025 as part of global tax reforms tied to the OECD’s Pillar 2 framework.

Bermuda repeatedly appeared in the filings analysed by the newspaper, particularly in relation to re/insurance structures. The article cited several examples, including Apollo Global Management and Athene, as well as pharmaceutical companies with historic Bermuda connections.

Even as the “tax haven” label persists, recent US Securities and Exchange Commission filings by Apollo suggest multinational companies are adapting to the new corporate income tax regime.

The firm disclosed a $1.7 billion accounting charge after determining that certain tax assets it had expected to use against future Bermuda tax liabilities were no longer likely to be realised. The filing points to the complex accounting and tax adjustments taking place as multinational companies adapt to Bermuda's biggest tax reform in decades.

The New York Times also highlighted how Pepsi’s units in Bermuda, Switzerland, Ireland and Singapore cut the company’s bill last year by nearly one third, or $691 million. The newspaper reported that Pepsi had shifted at least $7 billion in profit into a Bermuda unit via interest payments on a $26 billion intra-company loan.

AbbVie, which faced questions from US lawmakers last year regarding Bermuda-related tax practices, separately identified the island as one of only four foreign jurisdictions with a material impact on its effective tax rate in its 2025 annual report.

The filing disclosed a Bermuda tax-rate differential of $104 million and Bermuda-related valuation allowances of $286 million.

The new disclosures stem from accounting rules that now require companies to provide more detailed jurisdiction-by-jurisdiction information on tax impacts.

The newspaper’s report called attention to one example involving Abbott Laboratories, which reportedly shifted the tax residency of a subsidiary from Bermuda to Malta less than two weeks before Bermuda's corporate income tax came into effect.

According to the report, the subsidiary subsequently reported billions of dollars in income while based in Malta. The Internal Revenue Service is challenging aspects of Abbott's tax position, the newspaper reported.

Meanwhile, AbbVie’s 2025 10-K says its tax rate differed from the US statutory rate partly because of foreign operations with lower tax rates, the US global minimum tax, audits/settlements, credits and business-development activity. It also flags OECD Pillar Two and the January 5, 2026 “side-by-side agreement” as creating tax uncertainty.