A New York Times investigation has spotlighted Bermuda’s continued role in corporate tax planning, despite the island’s 2025 adoption of a 15% corporate income tax under the OECD’s Pillar 2 framework. The report analyzed SEC filings from major U.S. multinationals and found persistent tax advantages linked to Bermuda-based subsidiaries, particularly in re/insurance and pharmaceutical sectors. Companies including Apollo Global Management, Athene, Pepsi, AbbVie, and Abbott Laboratories reported significant tax impacts tied to Bermuda operations.

Pepsi reduced its 2025 tax bill by $691 million through profit shifts to Bermuda, including $7 billion moved via an internal loan. Apollo took a $1.7 billion accounting charge as it adjusted to the new tax regime, reflecting the broader financial recalibration underway. Meanwhile, Abbott Laboratories shifted a subsidiary’s tax residency from Bermuda to Malta just before the tax took effect, a move now under IRS scrutiny.

The increased transparency stems from new accounting rules requiring detailed jurisdiction-by-jurisdiction tax disclosures. While Bermuda rejects being labeled a tax haven, citing full OECD compliance, the data shows multinational firms continue to optimize tax outcomes using its structures. Uncertainty remains around OECD Pillar Two implementation and side agreements affecting future tax liabilities.