ARTICLE
14 April 2026

Bermuda's CITA Issues Notices To Undertake Independent CRS Compliance Reviews

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Walkers

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We are a leading international law and professional services firm providing legal, corporate and fiduciary services to global corporations, financial institutions, capital market participants and investment fund managers. With a global presence spanning the Americas, Europe, the Middle East and Asia, we advise on the laws of Bermuda, the British Virgin Islands, the Cayman Islands, Guernsey, Ireland and Jersey. With over sixty years of looking at the world through the same commercial lens as our clients means we deliver focused, clear, precise advice to get the deal done. Clients trust us to help them make good business decisions, create commercially sound products and strategies, resolve disputes and cement deals that are profitable. From offices across geographies, we deliver business-critical advice and service in the same time zones as our clients, covering asset management, investment funds, corporate, M&A, dispute resolution, finance, insurance, fintech, private capital and trusts, regulatory and more
On 13 March 2026, Bermuda's Minister of Finance designated Bermuda's Corporate Income Tax Agency (CITA) as the 'competent authority' under the International Cooperation (Tax Information Exchange Agreements) Act 2005 and the U.S.A.–Bermuda Tax Convention Act 1986.
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On 13 March 2026, Bermuda's Minister of Finance designated Bermuda's Corporate Income Tax Agency (CITA) as the 'competent authority' under the International Cooperation (Tax Information Exchange Agreements) Act 2005 and the U.S.A.–Bermuda Tax Convention Act 1986. CITA is a recently established statutory body and is now responsible for the administration and implementation of the Corporate Income Tax Act and international tax compliance functions in Bermuda. 

In its role as the competent authority in a Common Reporting Standards (CRS) participating jurisdiction, CITA has an obligation to ensure that the CRS requirements have been implemented effectively in Bermuda and to monitor Bermuda Reporting Financial Institutions (BRFIs) for ongoing compliance with CRS obligations. 

In its new role, CITA has already commenced issuing notices to selected BRFIs under the International Cooperation (Tax Information Exchange Agreements) Common Reporting Standard Regulations 2017 (as amended). Such notices require the BRFIs to undertake CRS compliance reviews. Selected entities must either appoint an independent reviewer to conduct the review or elect for CITA to conduct it. The notifications must be acknowledged within 10 days of the notice and the independent report must be submitted within 90 days. Independent reviewers must be approved by CITA.

We have a global Regulatory & Risk Advisory practice group of dedicated regulatory lawyers who are available to advise and assist with all aspects of compliance with Bermuda's CRS requirements.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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