Doing Business In... 2025

BAHAMAS Trends and Developments Contributed by: Aliya Allen, Alistair Chisnall and Michaela Sumner-Budhi, Graham Thompson

cases the investment must be held for a mini - mum of ten years. However, the government is narrowing the defi - nition of “owner-occupied” and removing its seasonality by replacing it with a defined time period for non-Bahamian resident homeowners. Non-Bahamian resident homeowners will now qualify for the partial owner-occupied exemp - tion for property if they stay more than 90 days in The Bahamas (annual real property taxes are tiered, and such homeowners will be entitled to complete exemption from property tax in respect of the first tier of BSD0–300,000). Non-Bahami - an homeowners that also occupy and reside in their residence for more than 183 days per year, will also be entitled to a maximum tax cap of BSD150,000 p.a. The government continues to prioritise the efforts to overhaul the conveyancing laws in the country. Working in close collaboration with the Land Reform Committee, and based on the Committee’s recommendations, the govern - ment has decided to move toward the adoption of systematically adjudicating all title to land in The Bahamas and establishing a Land Registry and registered land system. A Land Adjudica - tion Bill and Registered Land Bill have now been prepared and circulated. It is anticipated that the Bills will be tabled before parliament by mid-year with a view to be enacted as a matter of priority. Condo-Hotel Tax Previously, properties not owned by a hotel that form a part of a hotel’s bedroom inventory (con - do-hotels) were exempt from paying real prop - erty taxes, as they enjoyed the same benefits of various concessions and exemptions granted to the hotel or resort developer pursuant to the Hotels Encouragement Act. Effective as of 1 January 2023, a Condo-Hotel Tax at the rate of

75% of the residential property rate set under the Real Property Tax Act is payable on a unit if it does not report net VAT in excess of the Condo- Hotel Tax. The maximum annual Condo-Hotel Tax payable is currently BSD150,000 per annum. Corporate Income Tax Other than the Qualified Domestic Minimum Top- up Tax (QDMTT) discussed below, there are cur - rently no corporate withholding, payroll, or trans - fer taxes paid by companies incorporated and/or doing business within The Bahamas. Business operators require business licences to operate a business in or from The Bahamas. Business licence fees are, generally, calculated based on gross turnover. The tax applies to businesses with a turnover greater than BSD100,000, except where the business is an IBC (international busi - ness company) or a financial services entity, in which case no threshold applies. The government has implemented the QDMTT for large multinational corporations on 1 January 2025. The QDMTT applies to constituent enti - ties within The Bahamas that are part of a mul - tinational enterprise group whose consolidated revenue is greater than EUR750 million (or its equivalent in any other currency). In-scope con - stituent entities in The Bahamas will be liable to pay a corporate tax of 15%. It is expected that constituent entities will be able to set-off all amounts paid under the Business Licence regime against the QDMTT due and that they will be able to take certain deductions from QDMTT termed as “business incentives” which are now contemplated in the Business Develop - ment Incentives Programme Bill, 2025. Final Words on Enforcement The implementation of a corporate income tax represents a sea-change in tax law in The Baha - mas.

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