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Shafik Hebous
,
Cory Hillier
, and
Andualem Mengistu
Pillar Two rules of the Inclusive Framework agreement on a minimum corporate tax (known as ‘Global Anti-Base Erosion Rules’, for short GloBE) have important implications for the design of the corporate income tax. This chapter discusses these implications particularly from the perspective of low-tax jurisdictions. It argues that it is not possible to design a system that always guarantees generating exactly the bare minimum tax intended by the rules and motivates that this should not be the policy objective anyway. Importantly, if no profit tax already exists, countries need to consider whether to adopt one, and if yes, in what form. There is a case for introducing a general profit tax beyond the GloBE rules, together with a qualifying GloBE domestic minimum top-up tax as a backstop. The familiar alternatives of efficient economic rent tax designs, however, are no longer equivalent under the GloBE. In practice, given the specifics of the rules, an efficient rent tax on in-scope multinationals cannot be combined with a statutory tax rate below a certain cutoff, because the minimum tax becomes always binding. Under the GloBE, immediate expensing particularly maintains the time-value of fully deducting the cost of investment, without impacting the GloBE effective tax rate.
Fabio Cortes
,
Mohamed Diaby
, and
Peter Windsor
This Global Financial Stability Note studies the growing trend of private equity (PE) investments into the life insurance industry. PE companies’ investments in life insurers are integral to their strategic growth as PE firms evolve beyond the traditional leveraged buyout transaction to acquire diverse businesses across private credit, structured credit, private real estate funds, and private infrastructure funds. This note reviews the growth in PE investments through the lens of the diverse acquisition incentives and strategies, the consequent changes to asset allocation and investment strategies of the acquired life businesses, and potential prudential and policy implications.
Mr. Philip R. Lane
and
Mr. Gian M Milesi-Ferretti
This note documents and assesses the role of small financial centers in the international financial system using a newly-assembled dataset. It presents estimates of the foreign asset and liability positions for a number of the most important small financial centers, and places these into context by calculating the importance of these locations in the global aggregate of cross-border investment positions. It also reports some information on bilateral cross-border investment patterns, highlighting which countries engage in financial trade with small financial centers.
International Monetary Fund
In the case of Bermuda, application of risk-based approaches seems particularly relevant not only to the insurance sector, but also to other types of financial and nonfinancial activities. The legal framework for investigation and prosecution of money laundering (ML) is well developed, and law enforcement and prosecutorial staff are highly motivated and professional. Bermuda’s Financial Investigation Unit (FIU) should be more adequately funded, staffed, and provided with additional technical resources, including, for instance, expertise in forensic accounting. A key strength of Bermuda’s supervisory regime is the integrated nature of financial sector supervision.
International Monetary Fund
This paper assesses the financial sector regulation and supervision in Bermuda in the context of the offshore financial center assessment program. The assessment reveals that the financial, regulatory, and supervisory framework is well developed in banking, the key areas of securities regulation, and antimoney laundering and combating the financing of terrorism (AML/CFT). Banking supervision is largely in conformity with the Basel Core Principles. The regulation of investment intermediaries and collective investment schemes, the main activities of the Bermudian securities industry, is working effectively. However, some deficiencies were noted in the assessment of insurance.
International Monetary Fund
This paper presents key findings of the Detailed Assessment of the Observance of Standards and Codes in the Financial Sector of Bermuda. The small number of licensed deposit-taking institutions in Bermuda are part of the broader financial intermediation sector. Typically, some 50 percent to 60 percent of the banks’ income is fee based. The value of client assets and the volume of their activities are the main generators of this income. Efforts to reduce employee and occupancy costs that reflect the high cost of doing business on the island are continuing.