The chief executive of Bermuda’s Corporate Income Tax Agency gave a pre-recorded speech at the PwC Summit on Wednesday because he is representing the island in France this week.

Mervyn Skeet was at the Organisation for Economic Co-operation and Development headquarters in Paris, attending a meeting with Working Party 11, consisting of technical experts from OECD member countries.

“I need to attend these meetings to make sure that we are represented correctly,” he said. “There is a lot of discussion right now on the side-by-side legislation, which has been initiated by the [United States].”

This is a proposed framework within the OECD’s global tax reform effort allowing specific countries, particularly the US and Britain, to have their existing domestic corporate tax systems operate in parallel with the OECD’s global minimum tax rules.

“It was initiated by the US,” Mr Skeet said, which does not want to have US-headquartered companies subjected to Pillar Two of the OECD’s international tax framework.

Side-by-side could eventually be extended to other jurisdictions, but for now it is focused on the US.

There has also been a focus on new systems of tax credits and the effective tax rate safe harbour, also known as the simplified ETR test, introduced by the OECD to streamline compliance with the global minimum tax.

“Those discussions will continue to take place during this period in Paris,” Mr Skeet said.

Bermuda's Corporate Income Tax Act 2023 became law in December 2024, allowing the island to apply a 15 per cent tax to large multinational corporations.

The first payment was made in September and the second one is due next month.

Mr Skeet took over the Corporate Income Tax Agency in January.

“CITA has been very focused on making sure that we have the right legislation in place, as well as giving people the ability to make payments,” he said. “The CIT Act was pulled together quite quickly in 2023. Everyone did a very great job of putting it all together, but there are bound to be amendments as we go along.”

Some regulation had been implemented around the tax refund reserved fund.

“This is a really important piece of legislation,” Mr Skeet said. “It manages where money sits before it goes across to the consolidated fund.”

The CITA has grown to 12 staff members and is recruiting to build out the team.