Apr 2026
Corporate Redomiciliation and Tax Strategy in the Maritime Industry
In recent years, the cruise ship market has witnessed a significant shift in corporate strategy, with major cruise companies increasing their presence in Bermuda through the redomiciliation of corporate entities. Industry giant Norwegian Cruise Line strategically moved its group companies from jurisdictions including the Marshall Islands and Delaware to Bermuda in 2022, joining Viking and Virgin Voyages who were already domiciled in Bermuda.
In December 2025, Carnival announced its intention to redomicile Carnival Corporation from Panama to Bermuda in May 2026, joining brands within its group of companies including Princess Cruises, Holland America Line and Seabourn Cruise Line. This trend is rapidly positioning Bermuda as the primary jurisdiction for cruise company corporations.
Tax Framework Driving the Shift
Part of the appeal of Bermuda lies in its favorable corporate tax regime, particularly the Bermuda Corporate Income Tax Act 2023 (the “CIT Act”). The legislative framework allows corporations to qualify for an exclusion from corporate tax on international shipping income, provided they can demonstrate that the strategic management and decision-making regarding their vessels take place within Bermuda. These provisions have proven especially attractive to cruise companies seeking both operational flexibility and tax efficiency.
Bermuda’s CIT Act aligns with the global principles established by Pillar Two of the OECD’s Base Erosion and Profit Shifting (BEPS) framework. Pillar Two aims to ensure that multinational enterprises pay a minimum level of tax, regardless of where they operate. Bermuda’s legislation reflects these principles by imposing a corporate income tax on in-scope multinational groups and requiring evidence of genuine economic activity within its jurisdiction, thereby reinforcing Bermuda’s reputation as a compliant and transparent international business centre for maritime corporations.
In addition to the CIT Act, Bermuda is widely recognised as a first-class jurisdiction to do business, known for its stable English common law system, close proximity to the US and Europe and its robust regulatory environment and modern infrastructure.
Expansion Beyond the Cruise Industry
The trend of redomiciling corporate entities is not limited to the cruise industry. Other sectors within the shipping industry have also moved their corporate entities from jurisdictions such as the Marshall Islands to Bermuda, seeking to be domiciled in an internationally recognised business jurisdiction and benefit from the Corporate Income Tax Act. This broader migration underscores Bermuda’s growing influence as a global centre for shipping and maritime corporate structures, driven by its robust regulatory framework and alignment with international tax standards.