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Europe > Bermuda

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Cover IMF Working Papers
Deciphering the GloBE in a Low-Tax Jurisdiction
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.
Keywords:
Investment; Minimum Tax; Tax Competition; Rent Taxation; Cash-Flow Tax; International Taxation; scope multinational; profit tax; top-up tax; tax design; Corporate income tax; Allowance for corporate equity; Corporate taxes; Tax allowances; Global
Cover Global Financial Stability Notes
Private Equity and Life Insurers
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.
Keywords:
private equity; life insurance; leveraged buyout transaction; private credit; structured credit; private real estate funds; private infrastructure funds; life insurer; private equity company; life insurance insurance company; PE company; IMF Library; Global Financial stability note; Insurance companies; Insurance; Credit; Financial statements; Asset allocation; Global
Cover IMF Working Papers
Digital Tokens: A Legal Perspective
Mr. José M. Garrido
Tokens are units digitally represented in a distributed ledger or blockchain. The various uses of this technology have the potential to transform a wide array of economic activities, from traditional commercial transactions to sophisticated financial undertakings. This paper explores the similarities and differences of tokens with traditional legal instruments in commercial law and how tokens could offer superior solutions, provided that proper legal foundations are established for their operation, including aspects of the law of securities and consumer protection law.
Keywords:
Tokens; Commercial Law; Securities Law; Fintech; Consumer Protection; token taxonomy; non-fungible token; del Mercado de Valores; digital signature; token offering; aspects of the law of securities; Securities; Blockchain and DLT; Smart contracts; Virtual currencies; Securities regulation; Global
Cover IMF Staff Country Reports
People’s Republic of China–Hong Kong Special Administrative Region: Financial Sector Assessment Program-Insurance Core Principles-Detailed Assessment of Observance
International Monetary Fund. Monetary and Capital Markets Department
This Insurance Core Principles Detailed Assessment Report was prepared in the context of the Financial Sector Assessment Program for the People’s Republic of China–Hong Kong Special Administrative Region (HKSAR). The report describes that the insurance penetration and density in HKSAR is among the top 10 in the world. Foreign-owned insurers are dominant in the HKSAR insurance sector, and account for about 72 percent of total assets as at end-2012. The long-term insurance industry is highly concentrated, while the market share of general insurance industry is more evenly distributed. All except one of the top-10 insurance groups are all foreign owned, with much larger consolidated operations compared to their operations in HKSAR. The Insurance Authority is responsible for regulating and supervising the insurance industry of the HKSAR. It is supported by the Office of the Commissioner of Insurance, a government department in the HKSAR. A self-regulatory system is used to supervise the conduct of business of intermediaries.
Keywords:
ISCR; CR; insurance intermediary; risk management; insurance business; insurance group; holding company; corporate governance; long-term insurer; reinsurance arrangement; Insurance companies; Insurance; Virtual currencies; Solvency; Anti-money laundering and combating the financing of terrorism (AML/CFT); Global; Asia and Pacific
Cover IMF Working Papers
Cross-Border Investment in Small International Financial Centers
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.
Keywords:
WP; portfolio; holding; SIFCs; liability; Capital flows; financial centers; international investment position; BIS securities statistics; vis-à-vis SIFCs; portfolio equity share; SIFC Group; portfolio liability; Financial statements; Foreign direct investment; Offshore financial centers; Portfolio investment; Global
Cover IMF Staff Country Reports
Bermuda: Assessment of the Supervision and Regulation of the Financial Sector
International Monetary Fund
This paper presents an assessment of Financial Sector Supervision and Regulation for Bermuda. The Bermudian authorities have made impressive progress in developing and implementing a risk-focused approach to supervision across the range of their sectoral supervisory responsibilities. Full rollout of the risk-based regulatory system to all market segments is, however, required for achievement of comprehensive oversight of the market. To support the introduction of a formal risk-based supervisory system, the banking department has been restructured.
Keywords:
ISCR; CR; Bermuda; company; AML; market; Standard and Poor's; CFT regime; deposit company; reinsurance companies Ace Ltd; Bermuda insurance market; CFT policy formulation function; Bermudian company; Insurance companies; Insurance; Anti-money laundering and combating the financing of terrorism (AML/CFT); Mutual funds; Commercial banks; Global
Cover Policy Papers
Offshore Financial Centers - Report on the Assessment Program and Proposal for Integration with the Financial Sector Assessment Program - Supplementary Information
International Monetary Fund
This supplement reviews the data received thus far and the progress made by participating jurisdictions in their dissemination efforts. Data for major jurisdictions that declined to participate are also provided where it is available from published sources. In addition, data on a sample of advanced economies are provided for comparative purposes. The framework identified a minimum set of variables for dissemination and recommended that jurisdictions publish data on those variables although jurisdictions could choose to publish more. Tables 2 and 5 to 13 provide the data received on those variables. The framework also identified additional variables that were to be provided to the Fund to help Fund staff monitor developments in financial centers.
Keywords:
PP; banking sector; net asset value; financial service; twenty-seven jurisdiction; nonbank assets; reporting jurisdiction; liabilities to the fund; cross-border asset; vis-a-vis nonbank; Insurance companies; Commercial banks; Offshore financial centers; Insurance; Asset valuation; Western Hemisphere; Europe
Cover IMF Staff Country Reports
Bermuda: Detailed Assessment Report on Anti-Money Laundering and Combating the Financing of Terrorism
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.
Keywords:
ISCR; CR; line of business; white collar crime; CFT supervision; due diligence; mutual fund; AML Regulations; credit union; Anti-money laundering and combating the financing of terrorism (AML/CFT); Legal support in revenue administration; Terrorism financing; Terrorism; Money laundering; Caribbean; North America
Cover IMF Staff Country Reports
Bermuda: Assessment of the Supervision and Regulation of the Financial Sector—Volume I—Review of Financial Sector Regulation and 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.
Keywords:
ISCR; CR; reinsurance company; deposit company license; BMA bank supervision policy; corporate governance; due diligence; handling client assets; insurance supervisor; handling client asset; parent company; auditing firm; investment funds; insider trading; mutual fund; customer identification procedure; Insurance; Insurance companies; Anti-money laundering and combating the financing of terrorism (AML/CFT); Money laundering; Legal support in revenue administration; North America; Northern Europe; Global
Cover IMF Staff Country Reports
Bermuda: Assessment of the Supervision and Regulation of the Financial Sector—Volume II—Detailed Assessment of Observance of Standards and Codes
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.
Keywords:
ISCR; CR; business plan; banking group; senior management; accounting firm; insider trading; parent company; financial condition; investment funds; credit union; Guidance note; Insurance; Insurance companies; Anti-money laundering and combating the financing of terrorism (AML/CFT); Post-clearance customs audit; Legal support in revenue administration; North America; Western Europe