EG · 10-Q · 2026Q3 · Full report

Global Minimum Tax Changes

EVEREST GROUP, LTD. · 2026-10-30 · Importance 46 · Surprise 42 · In source text

Bermuda’s Corporate Income Tax Act 2023 applies a 15% corporate income tax to certain Bermuda businesses for fiscal years beginning on or after January 1, 2025. OECD guidance issued January 15, 2025 restricts the use of certain Bermuda transition-related deferred tax benefits against Pillar Two global minimum taxes to approximately 20% of the originally calculated amounts, and only through 2026; Bermuda amendments could reduce Everest’s deferred tax assets. The OECD issued further global minimum tax implementation materials on September 11, 2026, which Everest is evaluating. Separately, a U.K. tax-law change effective March 20, 2026 produced an approximately $40 million one-time tax benefit, while U.S. disavowal of the OECD framework and potential responses could create uncertainty and increase taxes.

Key facts

• OECD guidance issued January 15, 2025 restricts use of deferred tax benefits from Bermuda’s Economic Transition Adjustment against Pillar Two global minimum taxes to approximately 20% of originally calculated amounts and only through a two-year grace period ending in 2026. source
• Bermuda’s Corporate Income Tax Act 2023 imposes a 15% corporate income tax on certain Bermuda businesses for fiscal years beginning on or after January 1, 2025. source
• On September 11, 2026, the OECD released additional global-minimum-tax guidance and implementation materials, including an updated GloBE Information Return incorporating the January 2026 side-by-side package. source
• If Bermuda amends its 2023 Act in response to OECD guidance, the impact is uncertain and could reduce Everest’s deferred tax assets. source
• Uneven OECD-framework enactment across jurisdictions and the U.S. response could create uncertainty and increase Everest’s income taxes. source
• Everest continued evaluating the potential impact of the September 2026 global-minimum-tax developments and monitoring further guidance and implementation in jurisdictions where it operates. source

Impact estimates