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Bermuda Fund Domicile

medium confidence — compiled with source citation from the investment brain.

Bermuda Fund Domicile

Bermuda Fund Domicile

Bermuda is a niche-but-material domicile — a small general-fund book (about 777 funds, roughly $310bn NAV) bolted onto a globally dominant insurance-linked-securities and reinsurance infrastructure. It is for funds that touch insurance risk — cat-bond issuers, reinsurance sidecars and collateralised quota-share vehicles — not for general hedge or private-equity strategies, where Cayman remains the default. ^[reports/Fund domicile profiles/Bermuda.md]

FieldDetail
Legal postureBritish Overseas Territory; common law; tax-neutral (out of scope of the 2025 CIT)
RegulatorBermuda Monetary Authority (BMA)
Tax headlineNo CIT/CGT/WHT for out-of-scope entities; 15% Pillar-Two CIT from 2025 for groups at or above €750m; tax assurance to March 31, 2035
Market rank/share93.2% of global cat-bond issuance listed (BSX 2025); about 92% of global alternative capital (ABIR 2024)
Signature vehiclesExempted company, Segregated Accounts Company (SAC/ISAC), Special Purpose Insurer (SPI)
Killer app3-day SPI approval for collateralised cat bonds and sidecars

^[reports/Fund domicile profiles/Bermuda.md]

  • Exempted company — open-ended and mutual funds, ILS issuers
  • Exempted partnership, LP and unit trust — closed-end private capital and Japan-facing unit trusts
  • Segregated Accounts Company (SAC, 2000) and ISAC (2019) — ring-fenced cells for sidecars and multi-series cat-bond issuers
  • Special Purpose Insurer (SPI, 2008) — single-deal cat bonds and sidecars, fully funded and perpetually solvent
  • Collateralised Insurer (CI) — reusable collateralised sidecar platforms

Bermuda has no Class I or Class II labels. The current split is Registered funds (Private, Professional A and B, Professional Closed) versus Authorised funds (Institutional, Administered, Specified Jurisdiction, Standard). ^[reports/Fund domicile profiles/Bermuda.md]

Tax posture

  • No income, capital-gains or withholding tax for entities outside the 15% CIT scope, and no exchange controls
  • The Corporate Income Tax Act 2023 applies 15% to Bermuda entities in groups at or above €750m revenue from fiscal years beginning January 1, 2025 — the enacted Pillar Two domestic minimum tax
  • Every out-of-scope exempted undertaking holds a Tax Assurance Certificate shielding it to March 31, 2035
  • US taxable investors face the same offshore-corporate PFIC and CFC caveats as Cayman; US tax-exempts route through blockers
  • No meaningful treaty network — a permanent limitation

^[reports/Fund domicile profiles/Bermuda.md]

Why chosen, when not

  • Choose specifically where the fund touches insurance risk — the ecosystem, rating-agency familiarity and the 3-day SPI pipeline repay the friction
  • Avoid for plain hedge, private-equity or private-credit funds (Cayman wins on familiarity and scale), or where cost and speed on ordinary funds matter (no shelf entities, pre-consent required)

Structure roles

  • Fills the insurance-linked SPV, issuer and sidecar layers: an SPI issues limited-recourse cat-bond notes and a CI runs reusable sidecar platforms
  • Does not serve the master-feeder or blocker roles that Cayman and Delaware occupy for conventional funds

^[reports/Fund structuring tax jurisdictions.md]

Market data

  • 777 funds and $310.5bn NAV (Q3 2025), essentially flat through 2025
  • ILS funds were about 8% of regulated funds (Q4 2025, up from 4.4% in Q4 2023), and 6.1% of NAV
  • The Bermuda Stock Exchange listed 93.2% of global ILS issuance, $65bn nominal and 746 listings (2025)
  • Record $25.6bn new cat-bond issuance in 2025 (up 45% year over year); outstanding market $61.3bn

^[reports/Fund domicile profiles/Bermuda.md]

Regulatory weather 2023–2026

  • Enacted: Corporate Income Tax Act 2023 (Pillar Two, from 2025)
  • Enacted: Economic Substance Act 2018 (funds generally out of scope)
  • Enacted: Beneficial Ownership Act 2025 central register
  • Not blacklisted — absent from the EU Annex I list (October 16, 2026); precise current Annex II grey-list status not cleanly confirmed
  • Pending: BMA 2025 consultation on principles-based sustainability disclosure for funds

^[reports/Fund domicile profiles/Bermuda.md]

Watch items

  • Insurance-cycle dependence — ILS and cat-bond flow is rate-sensitive and cyclical, not steady-state
  • Size asymmetry — about $310bn versus Cayman trillions; thin general-fund proposition
  • The March 31, 2035 tax-assurance cliff — after that date neutrality is policy, not contract
  • Annex II grey-list membership is an unresolved uncertainty rather than a clean bill of health

See fund-domiciles for the decision matrix and fund-entity-stack for where the insurance-linked SPV and issuer layers sit. fund-domicile-cayman is the general-purpose offshore benchmark.

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